Fast Method To Define and Test Recall and Withdrawal Procedures
Fast Method To Define and Test Recall and Withdrawal Procedures
Fast Method To Define and Test Recall and Withdrawal Procedures
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Withdrawn/recalled products Same Other chapter 5.10 Management of 3.8 Control of 2.4.5 Non-conforming Product
and end products still in stock non-conformities and nonconforming nonconforming product or Equipment
shall be secured or held under products
Dealing with products the control of the organization
until they are managed in
accordance with 8.9.4.3.
shall verify the implementation Same withdrawal procedure shall be subject The product recall and The product withdrawal and
and effectiveness of to regular internal testing, based on withdrawal procedures recall system shall be reviewed,
withdrawals/recalls through the hazard analysis and assessment of shall be tested, at least tested and verified as effective
Verification of process use of appropriate techniques associated risks but carried out at least annually, at least annually.
(e.g. mock withdrawal/recall or once a year.
practice withdrawal/recall)
notifying relevant interested Same Snomination and training of a crisis A documented incident Records of all product
parties team, an alert contact list, sources of management procedure withdrawals, recalls and mock
Documented legal advice (if necessary), contacts is required; a recalls shall be maintained.
handling withdrawn/recalled availability, customer information, and documented product
information products as well as products still a communication plan, including withdrawal and recall
in stock; information to consumers. procedure.
BASICS OF WITHDRAWAL/RECALL PROCESS
Every withdrawal/recall process has five aspects:
1. What is done Which regulative in your country is defining recall process? Demands of regulative?
2. When Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 – Food Safety Law
/ ARTICLE 19 and ARTICLE 50
3. How ARTICLE 19. Responsibilities for food: food business ARTICLE 50. RAPID ALERT SYSTEM
operators
I3. Without prejudice to other Community
4. Why If a food business operator considers or has reason legislation, the Member States shall immediately
to believe that a food which it has imported, notify the Commission under the rapid alert system
produced, processed, manufactured or distributed is of:(a) any measure they adopt which is aimed at
not in compliance with the food safety restricting the placing on the market or forcing the
requirements, it shall immediately initiate withdrawal from the market or the recall of food or
procedures to withdraw the food in question from feed in order to protect human health and
the market where the food has left the immediate requiring rapid action;
control of that initial food business operator and
inform the competent authorities…
PHASES OF CONSTRUCTING THE WITHDRAWAL/RECALL
2. Organizational aspect
STEPS EXPLANATIONS
Internal procedures and
Is there already defined procedure? When was the last time procedure verified? Standard requirement?
standards
Company size and employee number; internal organization
Responsibilities
Food safety team members + top management; external responsibilities
Process
Production check Recall
Process
Warehouse check s
Recall
External Recall
PHASES OF CONSTRUCTING THE WITHDRAWAL/RECALL
4. Controlling aspect
STANDARD ALIGNMENT COMMUNICATION
Requirements fulfilled measurement Whether or not any to the hazard to those
Records available Process customers disease or injuries have individuals who may be
Process architecture & stakeholders already occurred from at greatest risk.
the use of the product. Assessment of the
Process output
Assessment of hazard to degree of seriousness of
various segments of the the health hazard to
population, e.g., children, which the population at
surgical patients etc., risk would be exposed.
GOVERNANCE who are expected to be Assessment of the
Process management Process metrics & exposed to the product likelihood of occurrence
decision making performance being considered, with of hazard.
particular attention paid
Process roles & Process management
responsibility controls
METHODS / PROCEDURES
Process design Process control &
& modeling measurement
Process implementation Process improvement
& execution & innovation
PHASES OF CONSTRUCTING THE WITHDRAWAL/RECALL
5. Safety aspect
PRODUCTION LANDING PROCESS
PROCESS Time for job processing
Production time Customer satisfaction
< Machine availability index
Time organization
EVALUATION- ADMINISTRATION
PROCESS PROCESS
Mock simulation Computer availability
Measurements in Number of open
process of recall and positions
traceability Time for expense
Mock effectivenes reports
Qualified staff
WITHDRAWAL/RECALL PROCESS LEVEL IN COMPANY
Process is implemented
department-wide. A
continuous review &
improvement
process is implemented to
Process is implemented. exchange lessons-learned &
(People assigned. address required changes
Communication to relevant proactively. Mock simulations
people done. are done in defined intervals.
Training done. etc.). Handled
Process is defined. There is recall and records available.
procedure and forms. Only team responsibilities.
Implementation is yet
missing or ongoing. Maybe
recall happened, but not
Awareness if process exists in followed as defined.
the organization.
(Planning) activities have
started for the definition of
the subject. No recall
No structured process happened or no records yet.
activities , steps are not
implemented, no standard
requirements or regulative
considered or known.
CASE AND CHECKLIST
Small food production company model (10-50 employees)
Define one responsible person/and replacement for process / Make a decision and communicate to organization
Make a list of regulative requirements that needs to be covered / Include regulative inspection as experts
Make a list of standard requirements that needs to be covered (customer, external consultant)
Define procedure for recall/withdrawal and communicate the same to organization (follow steps of process
definition)
Perform changes of transport, warehouse and production for proper handling with nonconforming product
Perform simulation minimally once per year (record time, actions for improvements)
If you answered “no" to most of these questions, consider familiarizing your self with the concepts and demands of recall/withdrawal
process.
CASE AND CHECKLIST
Medium and large food production company model (over 100 employees)
Define responsible team (responsibilities per department/process step) / Make a decision and communicate to
organization
Make a list of regulative requirements that needs to be covered / Include regulative inspection/agencies
Make a list of standard requirements that needs to be covered (customer, external consultant)
Define procedure for recall/withdrawal and communicate the same to organization (follow steps of process
definition)
Perform simulation minimally once per year in cooperation with customer and supplier (record time, actions for
improvements)
If you answered “no" to most of these questions, consider familiarizing your self with the concepts and demands of recall/withdrawal
process.
RECALL/ WITHDRAWAL – CRISIS COURSE
Differentiation of crisis depending of time of detection
(usual) Identification
potential
Crisis prevention
requirement
(potential) time
destructive effect
RECALL/ WITHDRAWAL – CRISIS COURSE
Course of crisis process with beginning, turning point and end
Begin End
SURVIVAL CHANCES
Turning point
End
CONSTRUCTING THE SIMULATION WITHDRAWAL/RECALL
Mock
STEPS EXPLANATIONS
Procedure / requirements Simulation is done according to predefined procedure and requirements of implemented standard
Simulation is performed minimally once per year, and each time there is change in
When to perform
system/process/product
Include traceability test (to ingredients, of ingredients and to customers, affected products)
Define product for recall and think about different reasons for recall
Include all departments, top management especially, and if possible suppliers and customers
A. Production Volume :
What should be considered
B. Remaining Stock Volume :
C. Distributed Volume :
D. Retention Volume :
E. Other usage (e.g. lab analysis, etc.) :
*** Note: Mock Recall must be completed within four hours of start time.
If Mock Recall is less than 100%, outline cause and indicate corrective action required:
KEY THINGS TO REMEMBER