What is the difference between a Traceability Activity and a mock product recall?
Many people get confused with what is expected to be undertaken when performing a traceability activity and a mock recall. First and foremost, it is important to understand what the difference is between the two activities. In the context of food certification, a mock recall involves testing all procedures that relate to recalling your food product from the marketplace. This includes all components of your recall plan including getting the recall team together, making the decision to recall, notifying the relevant authorities and stakeholders, drafting written communications, informing customers, retrieving affected product, allocating relevant compensation and performing finished product and raw material traceability.
A traceability activity is testing that your product can be traced to the customer (one-up) and by also tracing raw materials back to the supplier (one-down). If you were to perform a product recall in real life, you would need to be able to trace your product. So in saying that, the traceability activity is a vital component of the recall process.
Testing your Procedures
If your business is certified to any of the GFSI standards, including SQF and BRC, you are required to test your company procedures for product recall. This means ensuring that you can adequately undertake a food product recall to stop any further risk of illness or injury to your customers. Adequate traceability, in this aspect, is to know where your product went to and where it came from.
To undertake a test of your recall procedures correctly (AKA mock recall) you must include a traceability activity. The main purpose of product recall is to identify and remove affected product from the market place as quickly as possible. A traceability will allow you to work out what types, batch’s, products have been affected.
Forward traceability evidence activity to the auditor
When I audit this clause for both BRC and SQF (and WQA in Australia) the business is required to support their traceability activity with all relevant paperwork. This does not mean a one-page report from the business perspective. You need to show all paper work for both forwards and backwards traceability. For example, for a forward traceability activity, evidence (in the form or records, reports and/or statements) would include:
- Number of units manufactured on the day for each recalled product type
- List of customers who were sold the affected product
- The quantities of affected product that each customer received
- Reports on any affected product that has yet to be sent to customers. These maybe still stored in warehouse storage areas
- Any write-offs or stock waste that occurred for the finished product
- Reconciliation reports of units manufactured to units sold to waste to warehouse storage
Backwards traceability evidence
The paperwork that you would need to show for backward traceability including records, reports or documents relating to:
- Raw material supplier
- Raw material receival dates and quantities
- Manufacturing recipes / formulations with quantities and raw materials used
- Any rework or waste generated
- Work in progress identification to raw material batching
- Production records (including staff who were working on that shift)
Traceability during an audit
As an auditor for both BRC and SQF, I am required to assess the ability for the food business that I am auditing to be able to adequately trace their product. This means getting the business to do a traceability activity during the audit. This is in addition to the one that the business should have performed as part of their own verification activities. BRC certification requires this activity to be conducted within a 4-hour period.
We also look at “mass balance” which deals with the actual quantities of ingoing and outgoing. I am yet to see a traceability undertaken during the audit that is about to trace and quantify correctly (with suitable evidence).
Map your product traceability
If you are interested in knowing how to map your product traceability, let me know by clicking here. If you have got your traceability method down pat, share with others and leave a comment below.
Until next time, Amanda