The cost of a product recall can run into the millions – but what are the processes that can be put in place to prevent this? What are the checks and balances that bakers put in place?
The best place to start would be looking at the main reasons for recall; most will be due to foreign bodies notably small dimension plastics or similar that escaped the traditional detection systems which a baker will have in place (sieves, metal detection etc.) Product quality issues follow next with poor baking, poor colour finish, and mould growth on bread products which have been packed before the articles had cooled sufficiently to prevent condensation from forming.
If you have not already conducted your obligatory HACCP analysis and recognised the pre-requisite and critical controls / critical limits required please do so, or at least ensure you have these under review following each complaint you receive.
You should also conduct internal audits of your systems (documents and procedures) and rigorous GMP audits to identify potential foreign bodies (glass and brittle materials to mention one); allied with effective senior management commitment to weed out any issues that are identified. A fault reporting system backed by senior managers to encourage operators to identify and report issues is an effective means of keeping on top of problems as and when they arise.
Much of the industry is mechanized to a greater extent with weight checks aimed at pre baked raw materials which through experience / custom and practise producers have recognised as the minimum weights needed to get the finished product to its desired weight / size at the end of the baking / cooling process. Most seen use a mix and match of raw weight checks (by percentage produced) and final quality measurements to ensure specification is met using single point scales or possibly in line check weigher.
Customer requirements have driven the food industry towards third party certification to ensure that the concept of a ‘due diligence’ defence can be met by suppliers and by extension themselves. These standards, which are certified by accredited certification bodies, include BRC and other House standards and codes of practise (some accredited). Depending on the size of operation, customer types and needs these are available to meet most sizes of operation and budgets.
These standards are based on a HACCP assessment with supporting procedures and monitoring practises. Supporting this is a quality management system based around the concept of the ISO 9001 standard. HACCP is fairly well known with your local EHO driving the basic legal requirements.
One cause of certification non conformity is lack of adequate training by the HACCP team / leader. If you have to write the documents go for level three HACCP qualifications. If you are operating / managing the system at least level two. Review is a legal need and as above a complaint should trigger an internal review of your systems following the investigation.
Be mindful that the audit process can be best described as “death by a thousand cuts”, lots of what you may describe as stupid issues can drop you from a good A grade to C; examples include poor cleaning management, poor maintenance of the premises and plant, poor supervision of operators (dress, jewellery, hair nets). Not counting documentation that does not meet the standard each example will earn a non-conformity which will soon add up. See GMP and internal audits above.
If you are new to the audit process you should be advised that familiarity with the systems – training, implementation, supervision and a robust corrective action system – can take a while to bed in. Serious management commitment is needed to drive this forward.
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