2.12.2
Procedures of verification shall be established to confirm that the HACCP or food safety plan, including controls managed by prerequisite programmes, continues to be effective. Examples of verification activities include:
- internal audits
- review of records where acceptable limits have been exceeded
- review of complaints by enforcement authorities or customers
- review of incidents of product withdrawal or recall.
Results of verification shall be recorded and communicated to the HACCP food safety team.
3.7
Corrective and preventive actions
Fundamental
SOI
The site shall be able to demonstrate that it uses the information from identified issues in the food safety and quality management system (e.g. non-conforming products, internal audits, complaints, product recalls, product testing, second- and third-party audits and online reviews) to complete necessary corrective actions and prevent recurrence.
3.11
3.113.1
Management of incidents, product withdrawal and product recall
SOI
The company shall have a plan and system in place to manage incidents effectively and enable the withdrawal and recall of products should this be required.
3.11.2
3.11.2
The company shall have a documented product withdrawal and recall procedure. This shall include, at a minimum:
- identification of key personnel constituting the recall management team, with clearly identified responsibilities
- guidelines for deciding whether a product needs to be recalled or withdrawn and the records to be maintained
- an up-to-date list of key contacts (including out-of-hours contact details) or reference to the location of such a list (e.g. recall management team, emergency services, suppliers, customers, certification body, regulatory authority)
- a communication plan including the provision of information to customers, consumers and regulatory authorities in a timely manner
- details of external agencies providing advice and support as necessary (e.g. specialist laboratories, regulatory authority and legal expertise)
- a plan to handle the logistics of product traceability, recovery or disposal of affected product, and stock reconciliation
- a plan to record timings of key activities
- a plan to conduct root cause analysis and to implement ongoing improvements, to avoid recurrence.
The procedure shall be capable of being operated at any time.
3.11.3
The incident management procedures (including those for product recall and withdrawal) shall be tested, at least annually, in a way that ensures their effective operation. Results of the test shall be retained and shall include timings of key activities. The results of the test and of any actual recall shall be used to review the procedure and implement improvements as necessary.
3.11.4
In the event of a significant food safety, authenticity or legality incident, including a product recall, regulatory food safety non-conformity (e.g. a regulatory enforcement notice) or food safety-related withdrawal, the certification body issuing the current certificate for the site against this Standard shall be notified within 3 working days.
The company shall then provide sufficient information to enable the certification body to assess any effects of the incident on the ongoing validity of the current certificate within 21 calendar days. As a minimum, this shall include corrective action, root cause analysis and a preventive action plan.
3.5.1.6
The company shall ensure that its suppliers of raw materials (including primary packaging) have an effective traceability system. Where a supplier has been approved based on a questionnaire instead of certification or audit, verification of the supplier’s traceability system shall be carried out on first approval and then at least every 3 years. This may be achieved by a traceability test.
Where the supplier is not the manufacturer, packer or consolidator of the raw material (e.g. purchased from an agent, broker or wholesaler) and approval is based on a questionnaire instead of certification or audit, the verification of the traceability system shall be carried out on the last manufacturer, packer or consolidator of the raw material.
Where a raw material is received directly from a farm or fish farm, further verification of the farm’s traceability system is not mandatory.
How can you perform a "mock" recall if you do not know the ammounts/batches added to each run .
Assume you use the JULIEN calander for daily batch codes - IE L4001 is 01-01-24?
Couple clauses relating to TRACEABILITY ---- Will be a MAJOR if you cannot show evidence of at least x2 traceability studies Forwards & Backwards...
More if you make claims ie GF or Low-salt....