Empowered Traceability and Recall Plans
Effective Traceability and Recall
Traceability and Recall in the Food Industry is one important defence against major challenges. The ability to trace raw materials through your food supply chain permits you to quickly isolate specific lots of finished goods and bring them back in the event of a contamination or potential health hazard to consumers.
To implement an effective traceability plan, it is important to organize your operation in such a way that permits documenting receipt and usage of raw materials in various products.
Traceability can be done manually or through spreadsheets, or through specialized software that permits you to records and recall lot numbers of specific raw materials used. The method is not especially important, but the effectiveness is. Auditing bodies like the FDA or CFIA or private certifying bodies would like to see you be able to identify all products produced with an affected lot number within two hours.
Recall Plans
Traceability and Recall plans involve several aspects. The primary requirement is the formation of a team that has the ability and authority to make effective decisions and executes those decisions appropriately. Empowered employees will be able to gather the necessary information to take to their team leader. Roles involve: Identifying the nature of the Recall; Determining the involvement of Federal Agencies, Determining the affected products, Determining where the affected products are located; Contacting the clients and distributors who have affected products; Deciding whether to have affected product returned or destroyed on the spot; Alerting media; Involvement of legal assistance, Contacting Insurance; Determining the effectiveness of the Recall and taking corrective action to prevent future scenarios.
Training and Practice: Mock Recall
In order to conduct a Recall effectively, it is important to practice and test whether your written Recall Plan is actually working the way is was designed.
Auditing bodies want to see that your operation conducts a Mock Recall at least once annually and record the results and effectiveness.
After training your team, select a raw material at random, and choose a lot number that you have received in the past.
Advise your clients that you are conducting a mock recall, and follow the Recall procedure from start to finish, without actually retrieving the products. Record the percentage of product that you are able to “retrieve” in the supply chain to determine whether your Recall plan is working, and whether your lot number tracking is working the way it was designed.
Once you have etablished how effective the Mock Recall is, make the necessary corrections to your Recall plan to permit a better result if it wasn’t as effective as anticipated. This may be in your record keeping or in certain areas of your operation that are not working as designed.
Recall, Traceability and Legal liability
Having an effective traceability and recall program is not only a legal requirement, but it helps reduce insurance costs. The tested ability to identify and return potentially hazardous foods from the supply chain, lowers your insurance company’s legal liability and gives them the confidence that your team is in control of its risks.
Additionally, it gives your clients the confidence that your company is in control of its supply chain in the unlikely event of an emergency.
Reputation
Nothing destroys a company’s reputation faster than a Recall that makes Headlines. When a Federal Agency decides that a Recall needs to be published in the National Media because the Recall Plan is not in control, your organization now comes under the scrutiny or the national press, who can destroy your reputation much faster than you have spent building it.
It will force you to hire lawyers and PR professionals to help conduct damage control and prevent the destruction of your brand.
Although, in some rare cases this might be necessary, having control over your manufacturing and packaging processes, and building an effective Traceability and Recall Plan can help mitigate such potential disasters.
Common Recalls
The most common food recalls are due to unlabelled allergens.
It is a very preventable mistake for many companies, where basic due diligence in identifying and controlling allergens, along with a thorough review of product labels can help avoid such issues.
Less common are contamination with pathogenic bacteria like Listeria, Salmonella and E.coli.
Other Recalls may be due to contamination with foreign materials such as plastics, metal fragments, and glass.
Most Recalls are entirely avoidable with the building and implementation of an effective Preventive Control Plan.
Should you need help building a Recall Plan, implementing traceability or even building a Preventive Control Plan, please contact us here for a free consultation
Read more about Recalling Food Products at the CFIA link here