An Effective Traceability and Recall Program
Traceability is critical for consumer safety and is also a requirement of the new Safe Food for Canadians Act. These new regulations require all manufacturers to have a program that will have the ability to trace a product backwards to its supplier and forwards to the retailer and will need to have clear and readable records that show this. Retailers will also need to be able to trace product back to their original vendor. These traceability records will need to be maintained for a minimum of 2 years and you would are required to be able to conduct full traceability in under 4 hours.
In the recent outbreak with E.coli in flour it was critical for many manufacturers that used this flour to be able to trace the ingredient in all of their products to determine the particular production containing the affected flour. By ensuring a strong traceability program they could minimize the recall to ONLY the product that was affected. and by removing it as quickly as possible reduce the potential that a hazard reaches consumers and potentially makes them ill.
Most accounting or ERP programs are extremely helpful with traceability program and have the capability to trace ingredients from purchase through manufacture and through to retailers. But no matter what your size you can put measures in place to ensure that you can trace your product.
With 3 simple documents and one documented program you can maintain full traceability of your ingredients and packaging and be fully prepared for a potential recall. This would include a Receiving log, Formulation sheets and a Shipping log. This, along with a well documented procedure on what to do during a recall and you can have an effective program.
In the receiving log you should ensure that for all ingredients and packaging entering your facility the lot code is recorded on the log as well as the supplier. If you assign your own lot codes at receiving you want to be able to ensure that these lot codes can easily be linked to the lot codes that your vendor has supplied them. This can easily be captured within the receiving log itself.
In addition, the receiving log is an excellent place to capture information on the trailer conditions and the condition of the product upon receipt. You can capture temperatures if the product is temperature sensitive.
These are your production records, formulation or batch sheets. These record the recipe for each of the products that you produce and on which day it is produced. Each production run should have their own distinct lot code applied to them to ensure that you can easily distinguish which production runs are affected during a potential recall.
With the shipping log you will be able to identify which lot of finished product went to which customer. This may include supporting waybill and invoice documentation that supports which customer has received which product, how much and which particular lot code they received.
In addition, this log can document trailer conditions and the condition and temperature (if applicable) of your product when it leaves your facility.
Strong traceability / recall program
A well written Operating procedure outlining:
- how you trace ingredients and packaging and how you trace finished products.
- recall team and the responsibilities of each of the team members
- template forms that can be used in case of an actual recall i.e. Notice to Vendors, Letter to CFIA, Tracking recalled products, etc.
- CFIA contact information & other potential relevant contact information. e.g. laboratory services
In addition, you should test your program, at a minimum annually, to ensure that it is working and you can easily trace your product. This ensures that all team members are well versed in their responsibilities and that the program is functioning effectively.
If you feel that there is more that can be done with your program and you aren't sure where to start, feel free to email me at firstname.lastname@example.org or check out my website at www.fsrdconsulting.com.