13 replies to this topic

[Michael.Walker]

Hello everyone,

 

I’m currently working on enhancing our product recall procedures to ensure full compliance with the BRCGS Issue 6 standard. As part of this, I’m in the process of creating a mock recall test form for our products and would appreciate any guidance or examples from those who have gone through similar exercises. I know also that Issue 6 will be changing to 7 soon.

Specifically, I’m looking for:

• Example templates or forms used during mock recall tests.
• Insights on how to structure and execute the test effectively.

I'm struggling to make this flow correctly and starting to wonder if creating a form to fill out is too much?

 

Regards,

[Scampi]

Flow???  Not sure what you mean

 

Why don't you first try to FIND a random lot from 6 months ago and see what you are able to find, target should be a minimum of 96% of your inputs AND finished goods

 

You do need a record, but I think you're over complicating this

[Michael.Walker]

By flow I mean, having a template that when recall is initiated then template would walk the team through the process, but I am finding there's back and forth and information is found.

 

We have a custom software that details all of our batch information for our product, with box numbers and batch numbers. However its the reporting side that I'm wanting to improve. We recently had our BRC audit and was given a minor NC for the below.

 

3.13.7 - Last test of the withdrawal system included communication with the customer, but did not consider identification of suspected product and associated traceability. A summary of the actions with key timings and responsibilities is not produced.

 

 

We did a traceability exercise which detailed the timeline for the test which satisfied the auditor. But for withdrawal, we produced a detailed list of a batch of raw material and all the orders it went into. Following that we didn't go any further.

[Dorothy87]

hi

 

See doc attached, please bear in mind that this form is for BRC Food Safety issue 9 however, BRC packaging issue 6, Clause 3.13.7 looks very similar 

 

Ensure your form will follow procedure (BRC packing issue 6 - 3.13.5) 

 

 - identification of they key personnel involved in assessing potential recall, together with clearly defined responsibilities

- a communications plan that includes methods of informing customer and (where necessary) regulatory bodies in a timely manner.  

 

a good advice is to set a case scenario, for example certain no of (lets say 500 cases) of food grade bags produced on 01.01.24 were contaminated with chemical etc.. then organise a traceability and management meeting (whatever you have in your product recall management procedure)  

 

:) 

Attached Files

•  PRODUCT RECALL & WITDRAWAL FORM.pdf   53.9KB   45 downloads

[Michael.Walker]

Hi Dorothy87.

 

Thank you for the reply, the form is not too dissimilar from the one I have created, However the action plan and timeline is what I'm missing from mine.

 

We have a documented procedure that I'm using to ensure the template covers all areas required.

 

For case scenario, I have created a scenario that would also make us go back to the supplier as well as our customer.

 

Thanks

[Scampi]

you should target being able to identify ALL raw materials, finished goods AND shipments in 4 hours or less-industry standard golden rule

 

your exercise should always include 1 step back and 1 step forward

 

so if you're mock is on a raw material, who supplied it and when, and also into what finished goods and when did said raw material go

 

do not forget to include waste

[jfrey123]

I've never used a form for mock recalls (though I do admit liking the one that Dorothy87 posted).  In the handful I've done over the years, I've always opted for having a good SOP/Program that outlines the steps we will take and then I document those steps being taken in a hand typed report/memo format.  I write the scenario, document the time the recall team is notified, assembled, and then we run through what needs to occur while I document who is doing what at what time.  It includes documenting the start and stop time of the traceback steps, documents who starts reaching out to the affected customers (listing the contact emails or phone numbers we would have used in a real scenario), who pulled the press release template and filled it out, who notified FDA, our CB, and GFSI contacts, etc.

 

At the end, we list out what was "found" in our investigation to perform a root cause and develop the corrective action.  When I was primarily consulting, we had a couple companies actually change processing SOP's for real after a root cause from a mock recall exposed some gaps.  So long as the steps to take are clearly outlined in your recall program, I've never been challenged for not having a specific form to fill out so long as the written report shows those SOP steps being followed. 

 

I do generally like to have a form for documenting the traceability step: it's helpful because you might have lower level employees doing cycle counts of existing inventory or sorting through BOL's or something, and a form helps ensure they collect all of the relevant information.

[AtomicDancer]

We are SQF Based, but the requirements are similar.

We have a basic form, similar to the one posted above, but I also included the e-mail/phone call templates for sending to our certification body, to the FDA & USDA, as well as a customer template in our Recall SOP. This SOP is also where the contact information for the FDA, USDA, Certification Body, etc are located. No searching for contacts, the text is approved by our management so we are all communicating the same, pre-approved message, just add the name of who is being contacted, what product is affected, and add the appropriate signature.

[ChristinaK]

I've used a document similar to the one Dorothy posted, but it included a little extra.

Our SOP for recalls also included communication templates for Customers, IP-holders, SQF/BRCGS & CB, and FDA. The mock recall paperwork had tick boxes for using the templates in the SOP to write up mock communications for at least 1 of the 5 aforementioned contacts. That way we could see what a "real" communication may look like, and discuss if the templates need adjusting. The mock recall paperwork also included a tick box to verify that the contact information (email, phone, fax, mailing address) for the example contact is correct and current.

 

Of course, if you create a mock letter for a customer during the recall exercise, I suggest adding a watermark to the document that states it's for a mock recall exercise and not an actual recall event. Just in case the paperwork is misplaced, the watermark ensures that it won't be accidentally sent out, haha.

[Tony-C]

Hi Michael,

 

I quite like the form Dorothy87 has provided and that can be used as a guide to manage and log the recall process.

 

Where it is deficient is that a recall might be caused by a raw material and therefore a supplementary trace form would assist to identify all the finished product affected. Then, using mass balance exercise, you are able to identify all the finished products, containing the raw material in question, that need to be recalled.

 

An example is shown below, it would need to be adapted based on to reflect the trace required i.e. if the recall by a specific raw material, process fault or other reason.

 

 Product Recall Trace.png   585.66KB   1 downloads

 

I don’t know why anybody would not have a form, especially because in a real recall situation you want things all laid out for you rather than having to think too much about what you need to record and who you need to contact etc. As ChristinaK has posted having contact details to hand, either in your procedure or as an appendix to your form would also be useful.

 

Kind regards,

 

Tony

[Michael.Walker]

We created a mock scenario with one of our products that means the raw material was faulty. So this allows us to go back one step to the supplier. However going one step forward, all the finished goods that used this "faulty" materials is still in our warehouse and hasn't been shipped yet. 

 

Would this satisfy the test that we did not have to contact a customer? Or should we be picking an order that we know has been supplied?

[jfrey123]

I would pick a product that has shipped, strictly for the fact you're testing the "recall" portion of your system.

 

Testing an item that hasn't shipped yet is better suited for testing your crisis management program.

[Scampi]

I would pick a product that has shipped, strictly for the fact you're testing the "recall" portion of your system.

 

Testing an item that hasn't shipped yet is better suited for testing your crisis management program.

Both BRC and SQF require you to be able to go one step back and one step forward for traceability

That is separate from a mock crisis scenario

[jfrey123]

@Scampi:  Yes, I'm aware one step forward/back is related and required under traceability.  I was trying to have a bit of fun poking at how it's not really a test of a recall system if you're not practicing recalling anything.  Plants I've worked at do both a recall test with trace as well as one or more extra standalone traceability exercise(s) as part of ongoing training.

 

In addition to, and of course separate, from the requirements of the mock crisis scenarios 

Edited by jfrey123, 06 September 2024 - 04:11 PM.