PRP 10: Traceability, Recall, Returned Goods, Rejections/Non-Conform Products

Procedure for Recall and Traceability

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A clear and reliable procedure needs to be made for traceability. Via batch identification on the label, traceability should be possible for the production conditions and the used raw materials.

When there is an immediate danger for public health, the explorer should take the goods that are produced under similar technological conditions out of the market. The goods that are taken out of the market should be placed under the supervision of the authorities until they are destroyed. They can also be reworked in a way that safety is guaranteed and used for purposes different than human consumption, after agreement with the authorities.

Every company should establish a recall procedure. This procedure has to describe how it will be decided if a recall is necessary, in the case of severe contaminations of severe calamities.

A recall procedure should contain:

• A plan for an effective and fast recall
• Responsibilities and competencies of the recall coordinator and the recall team
• Traceability systems
• Emergency measures
• Information for the personnel of the company (intern)
• Information for the authorities, media, consumers’ organization, consumers, buyers, distribution, other involved parties (extern)
• Checklists, lists of contact persons, list of external experts
• Registration of information and evaluation
• Reporting
• Aftercare

Procedure for Returned Goods

A procedure for returned goods has to describe what to do when products are received as returned goods. Therefore, it is important that for every despatch of returned goods a return form is completed, that contains the following information:

• Serial number of the form, date
• Description of the product
• Return coming from
• Reason
• Responsible person
• Decision date
• Signature

It is essential that returned goods are analysed concerning food safety (and quality), that the cause is retrieved and when relevant, that corrective actions are taken to avoid analogue returns and recalls in the future.

The procedure should also include how a returned or recalled batch should be marked in a way that it is clear, and everybody can recognise it as a blocked batch. Also, the way of unblocking the goods should be included in the procedure.

Procedure for Non-conform Products

Non-conform products can originate everywhere in the process. When a deviation occurs during control at the receipt of raw materials, a deviation of one of the production parameters during production or by insufficient elaborated or controlled PRPs, a product is produced that does not correspond with the specifications or requirements.

As a consequence, a procedure should be available, in which it is described how products (raw material, intermediate product, either final product) that do not comply with the specifications should be handled. Aspects like blocking, unblocking and rejections should be discussed. When a nonconformity is found, the batch should be blocked. This can be done with red tape and clear identification of “blocked product”.

A registration form should be present in the company, to indicate the non-conformity and describe the actions that were taken. After the blockade of the product, it should be investigated how the product deviates from the specifications. This can be done by for example microbial or chemical analysis.

When the analysis shows that the product complies with the specifications, it can be unblocked. This should be clearly indicated on the registration form of non-conform products.