Having a properly working Traceability Program in place gives the facility the confidence that they can quickly define suspected raw materials, food contact packaging materials, rework and finished product.
From (food) legislation, over ISO to food safety standards, traceability is a mandatory requirement.
The traceability program needs to be described. This could be done in a procedure or instruction and should cover all requirements for tracing by batch number. As traceability exercise is the verification of the program:
An organisation very often performs a traceability exercise from finished product to raw materials, e.g. in case of complaints or nonconformances. But we also have to remember to carry out traceability exercises from raw material to finished product.
Traceability exercise: the details
What kind of data needs to be collected for a traceability exercise?
Traceability exercise from finished product to raw material should include as a minimum the following records:
Attention: Processing aids should also be a part of traceability program!
Traceability exercises from raw material to finished product should include the following documentation:
Attention: Tracing raw material can be tricky. This could involve one or more production runs. You have to include all production runs where the traced batch of raw material was used.
Critical is to have traceable lot numbers in each step of production and distribution. Each finished product, raw materials, packaging materials, semi-finished products, rework needs to include a unique code and records.
Attention: Also returned raw materials or packaging materials from production to warehouse needs to have full coding. Good practise is to use already opened on previous production run raw material or packaging material and to apply the First-In/First-Out (FIFO) principle.
A mass balance exercise is usually carried out as follows:
As a part of tracing a suspected product, a recall program should define the procedures for the quick and controlled removal of the product from the market. These procedures and their interaction are also tested during the mock recall. The traceability exercise is part of the recall procedure.
The minimum requirements for recall exercise:
Attention: Usually, a recall is understood as the return of suspected finished product as a consequence of a facility mistake/error. But the source of a recall can also be a critical problem of raw material or packaging used during production or failures in the supply chain.
Attention: The best way to cover this requirement is to collect emails with confirmation from all involved distributors.
The traceability systems ensure that a facility is capable of managing effectively the recall of product.
We would like to help you with an effective traceability or mock recall exercise: contact us for a practical approach and prevent issues: you don’t want to improvise during a crisis, so be prepared!