3 replies to this topic

[Tom M]

Dear all,

When doing an internal audit, i stumbled upon this section of the BRC/IOP standard version 3:

3.12.3 The recall prodcedure shall be capable of being operated at any time....
....Arrangements for notifying relevant stakeholders within a specified time frame shall be defined within the procedure (eg contact details)

Can anyone explain what exactly is meant with "shall be capable of being operated at any time" and "arrangements for notifying relevant stakeholders within a specified time frame"?
Who are meant with stakeholders. And how can you put a time on it? Any examples?


Thanks in advance,

Tom

[GMO]

From a food perspective, I would say it means if you make food with a supermarket's brand on it, you must be able to contact them and also the local authorities if necessary (those would be the stakeholders in my opinion).

Our customer says that we should be able to inform them of a potential recall situation within 20 minutes of us being aware of it whether that is day or night. I think within an hour is probably fast enough.

As you are asking in the packaging section; this is what I would do. I would have a crisis manual and all managers on site know where it is. Think about who would co-ordinate a fire evacuation any time of day or night, the same person could be your crisis manager.

In the crisis manual, I would put a list of contact details of senior managers in order of who should be contacted (probably Factory Manager, then Technical Manager), an explanation of what a crisis is (this manual could cover more than food safety). Then I would put in a checklist of what to do / what info to find out, e.g. batch codes and quantities affected, which customers have received product etc. but it needs to be emphasised that it's better to call all your customers if you don't know that than delay excessively. Then I would put in contact details (including out of hours) for all of your customers.

Once you have a manual in place, people will need training against it and it must be regularly reviewed (suggest monthly) as contact details change. I found two crisis manuals at my last place of work which were 3 issues out of date!

Then, you need to test your ability to recall product. To do this, get someone to chose a product or a customer batch, then you have to work out how much product could be affected and where all affected product has gone. You should aim to do this in 20 minutes ideally and if your traceability systems are robust, that should be possible. Remember you should test this on days, nights and at weekends and aim to do this probably every 2 months with different employees completing the task. What I always do is reconcile how much product I have made with how much I can account for through despatch to ensure that some hasn't gone to another customer by mistake. This can give you a percentage of your ability to recall product and a time it took which is easy to make into a KPI.

Hope that's helpful

Edited by GMO, 24 April 2008 - 07:13 AM.

[okido]

Hi Tom M,

Regarding the time to trace everything back, 20 minutes seems rather short to me.
In The Netherlands there is an un-official standard of 4 hours for every step in the food chain.

Have a nice day, Okido

[Charles.C]

Dear Tom,

Regarding the meaning of the word “stakeholder” this is actually an old word which has apparently become of significant importance in the business word (news to me !).

Wiki gives –

The term stakeholder, as traditionally used in the English language in law and notably gambling, is a third party who temporarily holds money or property while its owner is still being determined.
• More recently a very different meaning of the term has become widely used in management. In a business context, a "stakeholder" is a person or organization that has a legitimate interest in a project or entity. The new use of the term arose together with and due to the spread of corporate social responsibility ideas, but there are also utilitarian and traditional business goals that are served by the new meaning of the term (see Stakeholder theory and below).

More explicitly, Wiki gives –

A corporate stakeholder is a party who affects, or can be affected by, the company's actions. The stakeholder concept was developed and championed by R. Edward Freeman in the 1980s. It has gained wide acceptance in business practice and in theorizing relating to strategic management, corporate governance, and business purpose (See Stakeholder theory).

A narrowly defined list of stakeholders might include:
• Employees
• Communities
• Shareholders
• Creditors
• Investors
• Government

Broader lists of stakeholders may also include:
• Suppliers
• Labor unions
• Government regulatory agencies
• Industry trade groups
• Professional associations
• NGOs and other advocacy groups
• Prospective employees
• Prospective customers
• Local communities
• National communities
• Public at Large (Global Community)
• Competitors
• Schools

http://en.wikipedia....akeholder_(law)

http://en.wikipedia....der_(corporate)

(I noticed there is no specific entry for "The Press" ).

So I guess the width of the interpretation is up to you (in the absence of BRC)

Rgds / Charles.C

added - From memory, The Americans are a bit more systematic in that they (FDA probably) categorise recalls into classes, eg 1,2,3, depending on the event so as to prioritise groups of (specified) people to be conducted.

added(2) - regarding frequency of mock recalls, GMO offers a very responsible answer IMO. I suspect that many, perhaps smaller, enterprises will find once or twice a year is acceptable to BRC. Also, where exports are involved, any trial can become quite demanding (though no less important of course).