Mock Recall Process

Table of contents

Introduction. 2

Responsibilities. 3

Mock Recall Process. 3

References. 5

Attachments. 5

Example 1 - Upstream (Top Down) 6

Example 2 - Downstream-External 7

Example 3 - Downstream-Internal 8

Introduction

Definitions

The mock recall is an exercise to test and prove that the traceability system is implemented effectively.   Downstream – internal mock recall (bottom – up): One batch of a material is tracked from reception to the semi-finished or finished products. Process and analytical records corresponding to the material are retrieved.   Downstream – external mock recall (bottom – up): One finished product is tracked until change of ownership, i.e. until the entity to which it has been invoiced. Process and analytical records corresponding to the finished product are retrieved. Upstream mock recall (top – down): All ingredients of one finished product are tracked up the (vendor) batch number and vendor of the ingredient. Process and analytical records corresponding to the ingredient/material are retrieved.   Note: “bottom – up” and “top – down” is the SAP/GLOBE terminology.

Purpose of this document

This document describes the process for executing a mock recall and how to evaluate the effectiveness of the traceability system.

Scope

This instruction covers all products manufactured or distributed by Nestlé. In countries where mock recalls are prescribed by regulations, these prevail.

Target audience

This General Instruction is addressed to: § Technical Managers § Corporate Quality Managers § Corporate Supply Chain Managers § Distribution/Logistics Managers § Factory Managers § Factory Quality Managers

Responsibilities

Technical Manager

The Technical Manager of a Market/Region/GMB has the overall responsibility of ensuring that the resources are allocated and systems implemented to perform the mock recall.

Corporate Quality Manager

The Corporate Quality Manager of a Market/Region/GMB is responsible for organizing the mock recall, assessing the results and formulating eventual corrective actions.   He/she esures that the necessary trainings are conducted.

Factory Manager

The Factory Manager ensures that the resources are allocated and systems implemented to perform the mock recall in the factory.

Factory Quality Manager

The factory QA Manager ensures that the mock recall is carried out according to the indications received from the Corporate Quality Manager.

Supply Chain, Distribution/Logistics Manager

The Supply Chain and Distribution/Logistics Managers are responsible to deliver the requested data during the exercise and for ensuring that resources are available.

Mock Recall Process

Frequency and Planning

At least one mock recall must be conducted annually. All manufacturing sites and distribution centers must be covered.   The mock recall must be announced in a way that excludes confusion with a real life situation.   A representative material/product must be chosen for the mock recall.   As stated in the chapter “Responsibilities”, the Corporate Quality Manager leads the whole process.

Description of scenario

The scenario or hypothetical reason of the “supposed “ recall must be clearly described to give all involved parties a picture of the information needed, e.g. “Allergen x missing on label of product xyz, batch, etc.” or “chemical contamination with compound x in raw material, etc.”.

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Mock Recall Process, Continued

Questions to be answered

The following questions must be answered during the mock recall:   Downstream – internal (bottom-up) § What quantity of the material in question has been received? § Are the results of the relevant analytical parameters of the material available? § Where and when has the material been used? § Are the results of the relevant process and analytical parameters of the receiving products available?   Downstream – external (bottom-up) § Are the process and analytical records of the material available? § What is the location (factory, distribution center, customer, transit) of the material in question? § What quantity exists in or has been dispatched to each location? § At what date did the first dispatch to a customer occur? (Is it possible that some product has been already consumed?) § Does the system information correspond to the physical stock? (Verify the physical inventory at 2 sites)   Upstream (top-down) § Are the relevant process records and results available for this product? § What are the ingredients of this product and which ones are relevant for the mock recall scenario? § Are the results of relevant analytical parameters of the concerned ingredients available? § Who are the vendors of the concerned ingredients?   See also the forms attached.

Results

The following figures must be calculated to judge the degree of success of the mock recall:   § % of product accounted for § Availability of analytical records § Does the system quantity correspond to the physical stock at the two sites? § Time required to collect the data

Targets

Internal targets must be set for accuracy (% of accounted products and availability of records) and time to collect the data.   Time targets might also be set by our customers or regulatory agencies.

Evaluation and continuous improvement

The exercise must be evaluated and an action plan established. Results and outcome are discussed in the MRQ.

References

Documents

§ GI-31.115, Traceabilty System § GI-31.103, Guideline on Crisis Preparedness and Management § GI-31.097, Handbook for Crisis Preparedness and Management § GLOBE QRC for Recall and Mock Recall Exercise § GLOBE QRC for Recall quantity reconciliation § GI-31.200, Nestlé Food Safety Management System § ISO 22000, Food Safety Management Systems-Requirements for any organization in the food chain

Attachments

Examples

Mock recall - Examples

Example 1 - Upstream (Top Down)

MOCK RECALL Results upstream – top down

Date 06.02.2008 Time 13:45

Section 1. BASIC DATA
PLANT	WISTERY
MATERIAL	Beef Soup Mix bulk 1x25kg
SAP Number
BATCH NUMBER
SLED (BBD, Use By or Exp. Date)
Hypothetical Reason	Pathogen presence
Materials with deviations	To be confirmed (use the “where to use” list)

Section 2. MATERIALS USED
Qty. Produced (1)	12000 kg
Beef extract (Liebig)	400 kg batch xyz, 200 kg batch abc
Onion powder (Tro-Kost)	240 kg batch abc
Leek granules (Tro-Kost)	120 kg batch xyz
Hydrolizate RFB (Givaudan)	400 kg batch abc
Other Materials used	See attached list (not shown)

Section 3. TIME REQUIRED(from the notice up to the reception of the documents)
Hours/Minutes	1:30

Section 4. DOCUMENTATION
Item	Documentation	required	accounted	Result
Critical raw materials	· COA			100%
Other materials	· COA			75%
Process (Line Controls) and Inspections	· Organoleptic · Microbiological · CCP records · Release/UD code	X X X x	yes yes yes yes	Ok Ok Ok Ok
Finished Products involved	· Release/UD code · Micro Monitoring	X X	Yes No results	Ok See below

Section 5. CONCLUSIONS AND ACTIONS

Objectives achieved   The requested micro monitoring results of finished products are not foreseen in the inspection plan. This is accepted as the line is monitored correctly.  

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