Product Recall is...
There are many types of product recall plans and obviously in our package, we are referring to a food product recall here! So now you may ask: “What is a food product recall??”
A food product recall is a request that a batch or an entire production run of a food product be returned to the manufacture, usually due to complaint or notification of product defects. The recall is an effort to limit liability for corporate negligence (which can cause costly legal penalties) and to curb bad publicity. Recalls are costly to a company because they often entail replacing the recalled product or paying for damages caused in use. These procedures are based to a large extent on product recall procedures undertaken by the producer, distributor or importer.
Product recall is indicated when a product may represent a health hazard to the consumer. The procedures implemented should effectively remove the product from circulation to prevent its consumption and are based to a large extent on product recall procedures undertaken by the producer, distributor or importer.In certain instances, government agencies may initiate a product recall, or take appropriate corrective action when a recalling firm's performance is judged inadequate. In addition a government agency may take enforcement actions either during or following the recall.
So how do we conduct a product recall plan??
1) Planning and Preparation
It is essential that all operators from producing, importing, or distributing products take precautionary steps to facilitate actions if recall procedures become necessary. An operator that sells products shall put into place procedures and systems that will ensure a rapid and effective recall of the product. To achieve this goal, the operator shall:
Prepare & maintain a detailed written recall system or plan: This plan or system has to describe, step by step, the procedure to follow in case of a product recall. It should also include the identification of responsible individuals, both within the registered establishment and from the outside, along with their respective telephone numbers, facsimile etc.
In order to evaluate the product recall program, periodic simulations should be carried out. The recall simulation file should include the name, address and telephone number of clients for the lot tested, production records, the inventory, and distribution of each lot distributed. The recall simulation is used to determine whether the recall procedure is capable of identifying and quickly controlling a given lot of potentially affected product and reconciling the quantities produced, quantities in inventory, and quantities distributed. A recall simulation will identify potential problems and allow personnel to become familiar with recall procedures. If problems are identified in the recall procedures, they should be corrected.
2) Notification
Once a firm has gathered all relevant information and assessed the situation, the next step is to notify the Executive Director, Operations in its area.
3) Necessary Information
Rapid and accurate information gathering will expedite both decisions regarding the need for recall, as well as the actual response. It is understood that information gathering begins upon first notification that a potential issue may exist and continues throughout all steps of an emergency response.
Useful information to gather includes the following data and answers:
reason for the recall - the actual or possible prevalent problem and the events leading up to the recall;
product identification - product name, company number (Canadian or abroad) and identification codes, dates of production, importation or exportation, etc;
type of product involved;
brand name;
net contents/size/weight;code/lot numbers or other distinguishing marks;
imported or domestic product;
quantity of the product in question and distribution: i.e. initial quantity of suspected product, quantities of the retained and distributed product (local, provincial, national or international distribution);
distribution date - regions, provinces or cities, countries, names of the manufacturers, distributors, etc;have any illnesses/injuries been reported and, if so, what were the symptoms, dates and times of onset, hospitalization, recovery, etc;
what are the possible causes of the problem;
are there any trends developing, is the problem growing, does it appear to be contained, etc;
has there been any laboratory confirmation of the hazard and, if not, when will it be initiated and when will the results be available;
are there any real or potential threats to human health or any deaths;details of the recall strategy - extent of the recall, methods of communication, recall warning;
has this product previously been involved in a similar incident or incidents.
4) Recall Strategy
(1) Depth of recall
This is dependent upon the degree of danger associated with the product and the extent of the distribution. Generally the depth of recall will fall into one of the following categories:Class I - consumer or user level, including any intermediate wholesale of retail level;Class II - retail level, including any intermediate wholesale level;Class III - wholesale level.
(2) Communications
The operator is responsible for promptly notifying the inspector in charge and each of its affected accounts about the recall. Initial notification should be made by phone, telex, facsimile, etc., followed by a confirmation by letter. A recall communication must cover the following points:that the product in question is subject to a recall and provide all pertinent identification data together with the reason for the recall;that further distribution or use of any remaining product should cease immediately;where applicable and required as part of the recall strategy, that the direct account should in turn notify its accounts that received the product about the recall;specific instructions regarding what to do with the product;provide a ready means for the recipient of the communication to acknowledge receipt, to provide data on the volume of product on hand and to report on client accounts contacted, etc. (allow the recipient to place a collect call to the recalling firm).
(3) Effectiveness checks
The purpose of effectiveness checks is to verify that all consignees at the recall depth specified by the strategy have received notification about the recall and have taken appropriate action. The method for contacting consignees may be by personal visits, telephone calls, letters, or a combination of these. The recalling operator is responsible for conducting effectiveness checks.
(4) Public Warning
In cases where there is a serious health hazard, it may be necessary to issue a public warning via the news media either on a local, regional or national basis, as appropriate. This warning will generally be issued by the operator responsible for the recall procedure in both official languages.
5) Role of government agencies
As stated earlier, in most instances the role of government agencies is to review the proposed action of the recalling firm and to provide advice. This is done at the time that notification of the recall is received. In addition they will monitor the progress of the recall. In other instances the agencies involved may initiate a recall or take steps to supplement the recall action taken by the firm if it is judged inadequate.
In certain circumstances where the health hazard is very serious, the agencies may rule that a public warning is mandatory and may in some cases issue the warning themselves.1.17 Protocol for High Visibility IssuesAny situation which might have, for example, political, public health, serious economic or legal implications, should be considered as a high visibility issue. There may be occasions when routine situations, for one reason or another, escalate and reach the status of high visibility.Officers, when faced with a situation, should attempt to assess it fully and consider possible actions required to deal with it and its possible impact.
Adopted from: http://www.inspection.gc.ca/english/anima/meavia/mmopmmhv/chap1/1.16-17e.shtml
