EleMents In a ProDuct ReCall PlaN

It includes:

1. Recall Management Team
2. Recall Contact List
3. Product Recall Decision Tree
4. Scope and Depth of recall
5. Records
6. Products' Traceability
7. Recall Procedures
8. Returned Product Control and Disposition
9. Reviewing of Product Recall Plan

1. Recall Management Team
When an unsafe food product has been identified, a recall co-ordinator will be appointed to maintain and retain full documented evidence of all actions taken during the recall. Besides the co-ordinator, the recall team also consist of members from different departments of the firm; including production, quality control, purchasing and marketing, sales, legal services, accounting, technical, distribution and public relation departments. Recall team’s task is to evaluate whether the product constitutes a threat to the health or safety of the consumer and recommend whether a recall should be initiated and the appropriate recall strategy (Depth of recall, regulatory classification, public warning and effectiveness of checks performed).

2. Recall Contact List
An updated list of contacts is important in a recall as it allows effective and fast delivery of notices to put unsafe products off shelves as quickly as possible. The recall contact list usually includes recall team and senior management, suppliers of all ingredients, distributors, sources of technical advice and support (like laboratory facilities) and local regulatory authorities (Food Control Department; USA regulatory authorities: USDA and FDA).

3. Product Recall Decision Tree
A decision tree will be used so as to ensure a systematic and logical approach at whether to execute recall plan or not (Refer to Appendix 1 for the product recall decision tree). There would be different strategies for different classes of recall as follows:

a) Class 1 Recall:
Carried out when there is a reasonable probability that the use of product will cause serious adverse health consequences or death
- Immediate and rapid recall of all affected product from all levels of the distribution system down and including consumer level.
- Notification of local authorities. I.e. Food control Department.
- Issuance of a public warning by means of the press and radio

b) Class 2 Recall:
Carried out when defect products may cause temporary or medically reversible adverse health consequences and the probability of serious adverse health consequence is remote.
- Immediate and rapid recall of all affected product from all levels of the distribution system down.
- Evaluate the appropriateness of notifying the media with information concerning the recall

c) Class 3 Recall:
Carried out when defect products is not likely to cause health consequences, but violates some specific food regulation.
- Product is recalled to the wholesale distribution level unless circumstances warrant retrieval at consumer level.
- Notification of local authorities i.e. Food Control Department.
- No media notification is required.
- No effectiveness check is required.

4. Scope of Recall
The plan should outline how the establishment will assess the amount and kind of product that is implicated in a problem. To decide which batch of products should be recalled.

5. Records
A detail records of raw materials, processing and production, departure of products and initial distribution which would determine the causes of adulteration and help in defining the scope of recalls. Records should be kept for a period of time until the product exceeds its shelf life.

6. Products’ Traceability
Products’ traceability allows identification of unsafe products. It limits the scope of the recall and removes the products from sale quickly and accurately. Products can be identified accurately with product names, product description and batch codes.

7. Recall Procedures
A set of procedures on how products are to be identified, collected, disposed off and post-recall follow-up during a recall. Recall procedures include how communications are made between food manufacturers, distributors and consumers. (Refer to Appendix 2 for Product Recall Procedures)

8. Records of Recalled Products
Records help to ensure that the quantity of unsafe products distributed tallies with the quantities of recalled products. Furthermore, records also serve as a reference and would be needed to show to the local regulatory (Food Control Department) during recall follow-up.

9. Testing and Reviewing of Product Recall Plan
The plan should be examined for errors, particularly in the contact lists or in light of any changes in the company’s product recall or trading status. It is essential that a product recall plan is periodically tested using a ‘trial run’ or mock recall exercise. This can be considered as a validation of the product recall plan. This procedure should also be documented and held as part of the product recall plan itself. Companies that develop product recall plans but do not test them may face problems when a real food safety incident occurs. Food businesses involved in product recall should review the product recall process and amend the product recall plan if necessary.