11 replies to this topic

[rotiboy1002]

As you know, BRC standard stated that we are required to conduct forward and backward traceablility test. I just want to understand this right. Does that means we have to conduct forward and backward traceability test under a same mock recall? Is it a requirement to complete the forward and backward traceability test within 4 hours? For a forward-backward mock recall, do we start with a finished product or a raw material?

I find it rather hard to start with a raw material and trace all affected finished products. Then, from the finished products, trace backward to identify all raw materials utilized in those products and the receiving date of those raw materials. Doing all that within 4 hours is somewhat unachievable for a manual system.

[Charles.C]

As you know, BRC standard stated that we are required to conduct forward and backward traceablility test. I just want to understand this right. Does that means we have to conduct forward and backward traceability test under a same mock recall? Is it a requirement to complete the forward and backward traceability test within 4 hours? For a forward-backward mock recall, do we start with a finished product or a raw material?

I find it rather hard to start with a raw material and trace all affected finished products. Then, from the finished products, trace backward to identify all raw materials utilized in those products and the receiving date of those raw materials. Doing all that within 4 hours is somewhat unachievable for a manual system.

Dear rotiboy,

I agree the terminologies can be confusing. AFAIK, the items (Mock) Recall and Traceability are separate test issues for BRC although having some (tracing) overlap.

And Yes, it helps if everything is on a PC / software. (investment opportunity ?)

BRC appears (to me) to utilise “traceability” in a somewhat flexible way .within its own standard depending on the exact location. I presume your OP is referring to 3.9.2 (traceability) and 3.11.3 ([mock] recall) ?.

Two threads which I found useful for understanding above clauses' requirements are –

http://www.ifsqn.com...dpost__p__48267
(Maybe especially see post #7)

http://www.ifsqn.com...dpost__p__56015

The (AIB) attachments in this post give some background information on the interpretation of involved terms / quantities. Basic ideas are similar to BRC although there are some divergencies IMO, eg the "common misunderstanding" identified with mock recall is actually nearer the standard test procedure IMEX (rightly or wrongly ).(With a target time limit again specified) –

http://www.ifsqn.com...dpost__p__57633

Rgds / Charles.C

[George @ Safefood 360°]

Yes these terms can be confusing. The confusion I believe arises front he fact that Recall contains elements of traceability at least in the recall scenario where you need to identify where product has done and to whom and what went in to it and so on.

The key difference for me is the Recall requirements is intended to identify in a timely way product to be recalled and withdrawn from the market and the effective management of the process. An element of this is traceability.

The traceability requirements of the BRC is often call the vertical audit. It is intended to test the effectiveness of the system based on the unit batch number. The vertical audit checks all inputs and outputs relating to that batch including materials, processing requirements, quantities, controls, tests, people, mass balance and reconciliation.

George

[Cravin' Cajun?]

I agree with George...during our initial BRC audit last year, we were required to do a "vertical audit" just as George described and had 2 hours to complete this task. It was tough, but we pulled it off and obtained certification.

[kconf]

When doing forward traceability with mock recall, does the supplier of ingredient also have to be contacted or just the customer?

[G M]

When doing forward traceability with mock recall, does the supplier of ingredient also have to be contacted or just the customer?

 

None of our auditors has required that we actually contact a third party as part of a mock recall.  This is, in effect, simulated when you draft a brief narrative for the exercise and present the results to the auditor.

 

It is probably best practice to verify contact information as part of your annual review though.

[kconf]

Thanks GM. That's what I thought too. 

The auditor gave us a NC for not contacting customer as part of a mock recall. How do I prove that contact info was verified? Does it get documented somewhere? 

[jfrey123]

I've run QA for a spice plant that kept everything manually for receiving/shipping as far as production was concerned (we had a basic WMS software, but it was only used for accounting).  We kept receiving records on paper, recording input lots and output lots in our paper batch records, and could tie them to paper and electronic shipping records rather easily.  Our most difficult blends would have 11 ingredients, iirc, which could have multiple lot codes per item, but we never had issues getting the records together for a trace in the 2 hour windows offered by GFSI or customer auditors.

 

 

Thanks GM. That's what I thought too. 

The auditor gave us a NC for not contacting customer as part of a mock recall. How do I prove that contact info was verified? Does it get documented somewhere? 

 

The mock recall aspects get a little more complicated but depends on how far you want to take it.  For the purposes of a mock recall, I usually just write up a memo type document as I work, documenting the time each step being performed as I go:

 

Example:

12:05pm - Recall event discovered

12:20pm - Recall team assembled in meeting room

12:22pm - Product Trace initiated

12:50pm - Finish product fully traced, contacting customers

1:05pm - Customers contacted, raw material trace completed

 

So on, so forth, and obviously record more information in the document for each step.  I've gotten away with recording the customer's contact information in the record I was keeping ("simulated contacting Mr. So-n-so" and showing the email or phone number).  Auditors were more impressed with me actually calling the QA contacts of my customers, telling them that we're running a mock recall and I just wanted to verify we have the best and accurate contact information.  You document that as well, taking the chance to show you've updated information if your contact is no longer there or has a different phone number.

 

The key is that you fully simulate everything you would do in a recall.  If your production manager is responsible to verify inventory is gone, send him out to do it.  If your receiving staff is responsible for getting the shipping docs to you, make them do it.  And write it all up as it is happening minute to minute.

Edited by jfrey123, 16 August 2024 - 05:31 AM.

[lillabec]

Thanks GM. That's what I thought too. 

The auditor gave us a NC for not contacting customer as part of a mock recall. How do I prove that contact info was verified? Does it get documented somewhere? 

 

I have a "corrective actions" section on my mock recall cover page that states "Distribution centers were told to hold all remaining product, stores told to pull product from shelves, customers alerted of recall." That way the auditor can see that in the case of a real recall, we would be communicating with the customers, without actually having to communicate with the customer during the mock recall. Never had any problems with this.

[MDaleDDF]

Second time today, I agree with lilabec. 

The idea of actually calling a vendor or customer for a mock recall is insane to me.   I've never once had an auditor ask to do that.

[AltonBrownFanClub]

The idea of actually calling a vendor or customer for a mock recall is insane to me.   I've never once had an auditor ask to do that.

Multiple auditors have told me the same thing. They said not to contact our customers for fear of them initiating a REAL recall.

 

I typically reach out with something along the lines of "We are contacting you to verify this is the best line of communication."

No mention of a mock recall. This has been accepted. I just make sure to include the recall notice template that I would use during a real recall.

 

The FDA has templates you can use here: 

https://www.fda.gov/...l-press-release

[AtomicDancer]

We are SQF certified, not BRC, and for the Mock, we have a template script for e-mail contact to our certification body & one for our customers/suppliers. We contact the certification body, FDA, and WSDA saying we are conducting a MOCK recall and want to confirm the contact information. 

Our customer's order via phone or e-mail so we use that as "Current Customer Contact Info".

So far, this has been sufficient.