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Establish routines for tracking, recall and withdrawal

Areas affected by, and subject to guidelines from STAND are:

  • Guidelines for traceability, recall and withdrawal, and how these are legally rooted
  • Requirements for traceability of products and the product areas covered by guidelines
  • Requirements for traceability information and labelling
  • How to develop internal contingency routines for unwanted events or crises

 

Guidelines for traceability, recall and withdrawal

Guidelines have been developed for traceability, recall and withdrawal in the grocery industry.
The guidelines are to be understood as recommendations that actors must bilaterally agree on whether to be followed or not.

The guidelines are based on Norwegian and international provisions on food safety and traceability:

  • Norwegian Food Manufacturing Act and Food Safety (Matloven, January 1, 2004.)
  • EU Food Law (Regulation EC 178/2002, January 2002), including traceability provisions, valid from 1 January 2005.

In addition, the Product Liability Act also contains general rules on safety and liability for products (food and non-food) that are supplied in the market, and that there are special provisions for medicines that also regulate traceability requirements.

Mattilsynet (The Norwegian Food Safety Authority) has had the guidelines for review and contributed comments on relevant areas.

The guidelines are the industry’s interpretation of existing laws and regulations.
The guidelines have not been legally tested, and there is currently no legal practice in the area.
By introducing the simplest systems, the legal requirements for traceability according to the industry’s perception will be satisfied.
Some types of food may be subject to additional requirements for traceability from the authorities.

More about the legal aspects can be found in Legal aspects of guidelines for traceability, recall and withdrawal.

Goals for the guidelines
The guidelines aim to “help the actors to meet the consumer expectations for safe products».

Target group for the guidelines

  • Quality assurance managers
  • Supply chain / logistics managers
  • Managers for factory and warehouse
  • Customer and consumer services
  • Legal departments
  • Communications managers
  • IT
  • Persons responsible for implementing traceability solutions

The degree of implementation and the infrastructure a business has chosen determines what investments must be made.
The costs can be significant, but the cost of not having such a function or having inefficient systems can also be significant.

It is a common opinion in the grocery industry that the use of common guidelines and standards improves efficiency and reduces total cost in the value chain.

Requirements for traceability of products

The law requires that each company should have systems to document which products have been purchased from the individual supplier and which customer has purchased the company’s finished products. This also includes raw materials and other input factors covered by the legislation, ref.

Product areas covered by guidelines for traceability, recall and withdrawal.

The policies include traceability for:

  • commodities, plants, animals or food stuff
  • materials and objects that are intended to encounter, or may affect, commodities or food stuff.

The guidelines are recommended for foods and non-food products, except for pharmaceuticals.

Areas not described in the guidelines

  • Internal tracking systems
  • Fodder, allergic practices and agricultural practices, including the use of GMOs
  • Prevention of pollution (e.g. disinfectants)
  • Development and implementation of quality assurance in a company
  • Implementation of product and / or pallet labelling systems, etc.

The above areas are not described in the guidelines, but do not mean that there are no provisions or regulations for this elsewhere.

There is no requirement in the legislation for the types of systems to be used for this.
Traceability can be manually based in the simplest form, while others have an advanced IT system to follow up on this.

Central to the legislation is the duty of each company to undertake risk analysis over which health risks the products represent, and how the company will relate to this in terms of traceability.

Businesses can practice more comprehensive traceability systems than the minimum requirements of the law, but this is either based on self-imposed claims or agreements with, and orders from, the contracting parties.

Traceability
Traceability is based on following the physical commodity flow.
All parties should be able to track their products one step forward and one backwards.

Traceability one step forward:
Traceability one step forward means the address to which the products are delivered to.
An invoice system that contains information about item number / tradename, customer number / customer name and invoice date is sufficient to track a step forward in the value chain.

If your business has one batch concept, this should be included in the invoice, Despatch Advice or that the company’s own expedition system is directly linked to the invoice.

Traceability one step backwards:
Traceability one step backwards means the address the products are delivered from.
The company must provide a log of received products describing which products are purchased from whom and in what quantity on date.

If the addresses for where products are delivered from or delivered to are not in accordance with the legal ownership of the products and the invoice fee, this should be agreed separately between the parties.

Requirements for traceability information and labelling

The main purpose of tracking information is to provide a basis for effective withdrawal/recall of food and other products as a part of consumer expectations for safe products.

Traceability information also includes raw materials and other input factors used in the production of finished products, ref.

Product areas covered by guidelines for traceability, recall and withdrawal.

The policies include traceability for:

  • commodities, plants, animals or food stuff
  • materials and objects that are intended to encounter, or may affect, commodities or food stuff.

The guidelines are recommended for foods and non-food products, except for pharmaceuticals.

Areas not described in the guidelines

  • Internal tracking systems
  • Fodder, allergic practices and agricultural practices, including the use of GMOs
  • Prevention of pollution (e.g. disinfectants)
  • Development and implementation of quality assurance in a company
  • Implementation of product and / or pallet labelling systems, etc.

The above areas are not described in the guidelines, but do not mean that there are no provisions or regulations for this elsewhere.

Traceability information and labelling
EU Regulation 178/2002 requires the products to be labelled to enable traceability.
The labelling must be affixed to the product packaging and be readable.

The information that shall be marked on the product:

  • Supplier Name
  • Item number / tradename

In addition, the sender’s system must have an overview of which recipient the products have been sent to. The recipient must have an overview of which sender the products are received from.

Information that can be labelled on the products and which will simplify the work:

  • Best before date
  • Expiry date
  • Batch / Lot number
  • Identification of load carrier (eg pallet)

In addition, it is recommended:

Sender to register:

  • Amount sent
  • Shipping Date
  • Receipt Date (if known)

Recipient to register:

  • Amount received
  • Shipping Date (if known)
  • Receipt Date

How to develop internal contingency routines for unwanted events or crises

Unwanted events or crises usually comes unexpectedly. To ensure proper handling it is important to be well prepared. The company must in advance have thought carefully about the type of events that may occur. A contingency plan must be prepared that can handle the situation in a quick, correct and efficient manner.

As part of the emergency preparedness, many companies have created their own crisis teams where each member has clearly defined tasks and responsibilities, including for traceability and possibly withdrawal or recall of the company’s products.

Contingency plan

The procedures to be used in case of a crisis must be documented through a contingency plan. The contingency plan may contain the following:

  • Scope, goals and target group
  • Company policy regarding product safety
  • Definition of event and crisis
  • Description of the crisis team with roles and responsibilities clearly defined for each member of the team
  • Action sequence to be performed if an event / crisis occurs
  • A list of important contacts – internal / external
  • When a product withdrawal is to be put into effect
  • When a recall is to be put into effect
  • How to organize internal / external communication
  • Documented experiences from past events and exercises
  • Templates for internal and external communication
  • Registration and evaluation of events

The contingency plan must be updated regularly and distributed to all involved individuals.

Crisis team

Based on the contingency plan, a crisis team must be appointed, which is directed from a central coordination point. The team must decide which measures are to be taken. It must be clearly stated who should be the decision maker. Nothing must be done without the formal approval by the crisis team.

The overall area of ​​responsibility for the team is to organize, manage and lead:

  • Handling each event / crisis
  • Development, implementation and updating of internal instructions to be followed if an event / crisis occurs
  • Continuous training of persons involved in product traceability in crisis management
  • Regular exercises and evaluation of the measures in the plan
  • Development of internal and external communication plans to be used as an aid in handling an event / crisis

The crisis management team is a permanent prepared group based on the company’s management team, supplemented with necessary expertise (legal, information, sales / marketing)

The team must be known at all levels of the company. The members of the team must be able to be contacted at any time, and when necessary, appropriate alternatives must be available to cover all roles.

Contact lists

For the communication to go fast, a list of persons with contact details (phone number, mobile number, e-mail address and mailing address) must be prepared in advance. This applies to the crisis team, potential deputies, external advisors, public authorities, contacts in industry organizations, customers and the media.

Internal contact list:

This includes internal decision makers, as well as people who have expertise and can provide support. The list must be complete, updated and accessible to all affected persons in the company. The persons in the contact list must be able to be contacted by phone, mobile phone and e-mail at any time and be prepared to be assembled as a team to handle a crisis.

External Contact List:

Each company has an external interface that can consist of suppliers, customers, logistics services providers and IT solutions, consumers, public authorities, etc. These form an external network with persons to be contacted if an event / crisis occurs.

The crisis team is responsible for ensuring that the external contact list is complete, updated and accessible to all key people.

If possible, it is recommended to print the phone number (usually the consumer contact number) on the product Consumer Unit (CU), so that a consumer can call and ask questions or inform the company about a product failure or complaint.

Training

All persons who could be involved in product traceability and crisis management must be trained and kept up to date on changes in preparedness. The training includes:

  • Enterprise procedures for traceability, IT solutions, how to access necessary data etc.
  • Instructions for managing events / crises
  • Crisis team, participants, responsibilities and tasks
  • The role of the person being taught
  • Who to contact
  • Importance of coordinated actions and communication in the company
  • What to do and what to avoid
  • How to use the documentation
  • How to use product tracking and registration systems

Exercises

The training should include exercises for handling events / crises. These must be run regularly to improve the readiness and awareness of the crisis management team, key staff and external contacts.

Exercises are applicable in the following areas:

  • Product traceability
  • Crisis management
  • Withdrawal
  • Recall
  • Handling of products in quarantine

Such exercises should be:

  • Regular and realistic
  • Documented with a clear explanation of the context, the results, the deviation and the corrective actions
  • Based on templates that reflect the internal technical and organizational instructions
  • Performed with the closest parties in the value chain

Check list for emergency preparedness

The company should prepare a self-assessment check list to evaluate its own contingency routines in relation to what is considered best practice. ap:

Check list for emergency preparedness
Requirements / actions Score
Event / crisis management team is designated with clear description of roles and responsibilities
Internal guidelines for handling events / crises with clear withdrawal and recall procedures, event evaluation, etc. are fully documented
Contact lists are documented and distributed
Contact lists are made available to key trading partners
Each individual involved in handling events / crises and withdrawal / recall procedures understands the roles and scope of action
Training materials are developed
Involved persons are kept regularly updated
Regular exercises are held to test all contingency plans and how the crisis team works
Regular exercises with important clients and / or adjoining parties in the value chain are held

 

An appropriate score can be based on the following example:
0: No action taken
1: Plans have been established, but work has not started
2: Implementation has started to a limited extent
3: Full implementation has started
4: The plans are fully implemented