Food > Food Recalls / Allergy Alerts > Recall Plans FOOD RECALLS: MAKE A PLAN AND ACTION IT!
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RECALL MANAGEMENT TEAM |
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NAME | ALTERNATE PERSON | BUSINESS PHONE | AFTER HOURS PHONE | RESPONSIBILITIES DURING RECALL |
Person's name and position in the firm | a replacement individual in the event that the person is not available |
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the duties of the person during a recall |
Benefits
If you receive a complaint, it is important to record the complaint information, complete an investigation at your storage facility, and contact the CFIA. Early action on your part may enable you to discontinue distributing the product until it is determined that the product is safe.
Description
There are three main parts to the complaint file:
Recording of the Initial Complaint Information
The complaint should be recorded by a designated individual(s). It is important to include enough information so that the manufacturer of the product can start an investigation of the problem immediately. This may include but is not limited to:
1. Complainant details
2. What is the problem with the product, e.g. chemical taste, allergic reaction, illness, object in the food
3. Product details
4. Retail Details
5. Illness and Injury Details
6.Has the complaint been referred to anyone else?, e.g. the Canadian Food Inspection Agency or Public Health
Investigation at the Storage Facility
It is important when you receive a complaint to make sure that the problem with the product did not result from activities at your storage facility. Investigate the complaint fully. If you determine that the problem was caused by activities in your storage facility, contact the CFIA immediately.
Record in your complaint file:
Complaint Referral
If you determine that the problem was not caused at your storage facility, refer the complaint immediately to the manufacturer who produced the product.
Record in your complaint file:
Action Taken
Although the problem with the product may have been caused at the manufacturing plant outside of Canada, it is your responsibility to determine the action to be taken with the product. Where the problem could be of a health and safety concern, you must contact the Canadian Food Inspection Agency to ensure that your action decision is correct. Once the decision has been made you should record:
Benefit
If you suspect that you have distributed an unsafe food product, contact the CFIA immediately. The CFIA staff can assist you with your investigations and should be consulted on all health and safety corrective action decisions. Each area in the CFIA has a Recall Coordinator who will assist you in contacting CFIA staff to help you with your investigation and the collection of the information necessary to make the most appropriate decision. A list of CFIA Area Recall Coordinators is provided below. Since the list may change, it should be reviewed frequently. This list is available on the CFIA web site: www.inspection.gc.ca.
Description
Your CFIA notification contact list should contain the following information:
The current CFIA Area Recall Coordinators can be reached at these telephone numbers from 8h00 to 23h00:
Atlantic | 506-381-7683 |
Quebec | 866-806-4115 |
Ontario | 416-665-5049 |
Manitoba / Saskatchewan | 204-229-9896 |
Alberta | 403-661-7505 |
British Columbia | 604-775-6085 |
Benefits
Being able to identify which product(s) have to be recalled is a great benefit to your firm. It allows you to limit the scope of the recall and remove the product(s) from distribution quickly and accurately. If you cannot identify a specific product(s) you may have to recall more product than is necessary. Furthermore, incorrect identification of all of the product during the first recall, may lead to other recalls. To do this, you must be able to trace the products that you have received and distributed.
Description
To limit your recall to a specific product(s) you must:
Receiving Records
All products that you receive, should be identified with a specific lot code. You should have a system in place which identifies and records the lot codes of each product you have received from each supplier.
For each supplier you should document:
Benefit
When the product is being shipped out of your storage facility into the distribution system, the lot codes of each product should be linked to the accounts receiving that product. This completes the link of the product from supplier - to your firm - to the accounts. Keeping this link is important; it enables you to limit your recall to the specific accounts that received the product being recalled. Your firm should have a record system which can generate these records accurately and quickly.
Description
Your firm should be able to create a distribution list which is product and lot code specific.
This distribution list should include:
These distribution records should be kept for a period of time that exceeds the shelf life of the product. In some instances the period of time is specified in CFIA inspection manuals or by regulations. Check with the CFIA to ensure that you are maintaining your distribution records for the correct period of time.
Benefit
For your own protection, keep records of products that you have recalled from your accounts.
Description
Your recalled product records should contain:
Benefit
There are several activities which happen simultaneously during a recall. Having a step-by-step recall procedure will ensure that all of the activities are completed. This is the plan that you will action during a recall. A brief description of each of the recommended steps is included below. Further details on the parts of each step and how to action your plan are described in Tab 3 of this guide.
Description
The recommended step-by-step procedure is as follows:
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Benefits
Your firm is responsible for ensuring that all of the accounts which you shipped the recalled product to are notified about the recall. You must assess the effectiveness of your notification. The actual process of how to notify accounts is described in Tab 3 of this guide.
Description
The recall effectiveness procedure includes a plan to assess the effectiveness of the recall. Elements of the plan should include:
Benefit
During a recall, your firms recall management team will be busy putting your recall plan into action. This is not the time to find out that your recall plan is not working or that the plan does not provide the information you need to remove the unsafe product from the market completely and quickly. Testing your recall plan before you have to do a recall, enables you to identify and correct problems in your plan.
Description
Your recall plan should be tested on a regular basis.
When you test your recall plan, pick a lot code of a product which you know has reached the consumer market. Then test your system and record:
Tab 2 of this guide described how your firm can develop a written recall plan prior to having to conduct a recall. These written elements form the basis for:
All of these elements should be developed and documented prior to conducting a recall.
The goal of this section of the guide is to describe, in detail, each of the key steps your firm should take once it has been decided that a recall will be conducted. These recommended steps include the preparation of a Notice of Recall, and in some circumstances, a press release. Your firm should review these sections prior to conducting a recall so that you will be familiar with the document requirements and their purpose. It would be beneficial for your firm to maintain templates or to prepare sample documents that can be used as examples during a recall. This will speed up the process and ensure that all of the necessary information is included.
As illustrated on the following page, you will recall from Tab 2, page 10 Recall Procedures, that the recommended steps of conducting a recall are as follows:
Decision to Recall the Product(s)
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PROBLEM
IDENTIFICATION / DECISION TO RECALL PRODUCT(S)
Problems resulting in a recall may be identified by the importer, consumers or the CFIA. Once a product has been identified as being unsafe or violative, it is your firms responsibility to determine the nature and extent of the problem in a timely manner and to take prompt and appropriate action to protect the health of consumers. Where the problem is of a health and safety concern, you must consult with the Canadian Food Inspection Agency to ensure that your action decision is correct.
At the very beginning of the recall your firm must:
Notify the CFIA immediately when you suspect that your firm has imported and sold a product that may pose a serious risk to consumers. Provide the CFIA with the following information:
This information is pertinent for the CFIA to develop an accurate and complete risk management strategy.
It is your firms responsibility to ensure that all products which need to be recalled are identified. In addition to those products directly affected by the problem, your firm must:
It is your firms responsibility to ensure that products to be recalled that are in your firms control are not distributed. Your firm must:
The purpose of a press release is to alert the public that a product presents a serious hazard to health. Not all recalls require a press release; the CFIA will advise you when a press release is necessary. Where the CFIA is not in agreement with a press release prepared by your firm, the CFIA may issue a separate press release. An example template is provided in Appendix A. In addition, examples of press releases are available on the CFIA website at: www.inspection.gc.ca.
During this step, your firm must:
Using your distribution record system, produce a product and lot code specific distribution list which:
Provide the distribution list to your CFIA contact within 24 hours.
Your firm is responsible for immediately notifying all of the accounts that received the recalled product.
It is the responsibility of the CFIA to follow up with some of your accounts to verify the effectiveness of the recall. Where it is determined that the recall was ineffective, your firm may be required to repeat the recall process.
Your firm is responsible to ensure that recalled products do not re-enter the market.
The action to be taken on the recalled product should be approved by the CFIA.
STEP 11: FIX THE CAUSE OF THE RECALL
As the firm that imported the unsafe product, it is your responsibility for ensuring that all reasonable steps are taken to prevent similar recalls in the future.
Listed below are some common problems, potential impacts and recommended solutions associated with some of the steps in the Recall Procedures.
1. PRESS RELEASE AND NOTICE OF RECALL
Problems:
Potential Impacts:
Recommended Solutions:
2. PREPARATION OF THE DISTRIBUTION LIST
Problems:
Potential Impacts:
Recommended Solutions:
3. INFORMING THE CFIA OF A RECALL
Problems
Potential Impacts:
Recommended Solution:
4. IDENTIFICATION OF PRODUCT(S) TO BE RECALLED
Problems:
Potential Impacts:
Recommended Solutions:
5. NOTIFICATION OF CUSTOMERS
Problem:
Potential Impacts:
Recommended Solution:
6. CONTROL OF THE RECALLED PRODUCT
Problems:
Potential Impacts:
Recommended Solutions:
7. VERIFYING THE EFFECTIVENESS OF THE RECALL
Problems:
Potential Impact:
Solution:
FOR IMMEDIATE RELEASE
ALLERGY ALERT - UNDECLARED (Name of Allergen) IN (Name of Product)
(CITY), (DATE) -- (COMPANY NAME), (LOCATION) is warning consumers not to consume (BRAND NAME AND PRODUCT NAME) imported from (NAME OF COUNTRY) because it may contain (NAME THE ALLERGEN) which is not declared on the label.
The product being recalled is:
(DESCRIBE THE PRODUCT INCLUDING BRAND NAME, PRODUCT NAME, PACKAGING, SIZE(S). LOT #, UPC
CODE)
The product is distributed in (NAME THE PROVINCES) or across Canada.
(NAME THE PRODUCT) may cause a serious or life-threatening reaction in persons with allergies to (NAME THE ALLERGEN).
Consumers should (TELL CONSUMERS WHAT TO DO WITH THE RECALLED PRODUCT e.g., return to point of sale for a refund).
There have been (NUMBER) of reported illnesses associated with this product.
Consumers can contact (COMPANY NAME) by calling (PHONE NUMBER).
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For more information, media please contact:
(COMPANY CONTACT NAME)
(COMPANY NAME)
(CITY, PROVINCE/STATE, COUNTRY)
(DAYTIME PHONE)
(AFTER-HOURS PHONE)
URGENT - RECALL OF (Name of Product)
(NAME AND ADDRESS OF YOUR COMPANY)
(DATE)
Dear Customer,
or
Attention: (NAME OF CUSTOMER CONTACT)
(YOUR COMPANY NAME) is recalling the products listed below because they may contain (NAME THE PROBLEM, e.g. an ingredient which may cause an allergic reaction and is not declared on the label, bacteria, foreign pieces of material).
Product Name | Brand | Size | Code, Best Before date, UPC |
Please discontinue selling these products IMMEDIATELY by removing them from display, counting the amount in your inventory and storing them in a secure place.
Please contact all accounts to which you sell this product immediately and inform them of this recall.
(YOUR COMPANY NAME) staff will credit you for the recalled product. Please mark the product RECALLEDand (YOUR COMPANY NAME) staff will call you to arrange pick up.
IMPORTANT
Please record the time and date you received this Recall Notice and acknowledge receipt by
signing and faxing this document to (YOUR COMPANY NAME) at (YOUR COMPANY FAX NUMBER).
Date / Time Received:___________________ Signature:______________________
Name of store / Distributor:_______________________________________________
Thank you for your cooperation.
(Signature)
(YOUR COMPANY'S CONTACT, THEIR POSITION, YOUR COMPANY NAME)
Mandatory recall means a recall as per Section 19 of the Canadian Food Inspection Agency Act.
19.(1) Where the Minister believes on reasonable grounds that a product regulated under an Act or provisions that the Agency enforces or administers by virtue of Section 11 poses a risk to public, animal or plant health, the Minister may, by notice served on any person selling, marketing or distributing the product, order that the product be recalled or sent to a place designated by the Minister.
Product Withdrawal means a firms removal from further sale or use of a marketed product that does not violate legislation administered or enforced by the CFIA. It is not considered to be a recall.
Public Warning is a news release that pertains to a specific food recall. The title of this form of communication is WARNING/MISE EN GARDE. The public warning is issued for those recalls requiring the recall of a product to the consumer level.
Recall (verb tense) means for a firm to remove from further sale or use, or to correct, a marketed product that contravenes legislation administered and/or enforced by CFIA.
Recall (noun tense) denotes the process of recalling the affected product and encompasses all tiers of the affected product distribution system.
Recall Classification means the numerical designation, i.e. Class I, Class II or Class III, assigned by the OFSR to a particular product recall to indicate the relative degree of health risk presented by the product being recalled.
Recall Depth means the level to which a recall is conducted (consumer, retail, distribution).
Recalling firm denotes a responsible firm which is accountable for the implementation of a recall.
Stock Recovery means a firms removal or correction of a violative product that has not been marketed or that has not left the direct control of the firm. It is not considered to be a recall.
Violative Product is product that violates legislation administered or enforced by the Canadian Food Inspection Agency.
Voluntary Recall means a recall that is initiated and carried out by the recalling firm without ministerial order.
"Class I" | is a situation in which there is a reasonable probability that
the use of, or exposure to, a violative product will cause serious adverse health
consequences or death. |
"Class II" | is a situation in which the use of, or exposure to, a violative
product may cause temporary adverse health consequences or where the probability of
serious adverse health consequences is remote. |
"Class III" | is a situation in which the use of, or exposure to, a violative product is not likely to cause any adverse health consequences. |
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