You want me to do WHAT?!
One of the most critically important parts of Canada’s new Safe Food for Canadians Act and Regulations is the need for a written, tested, and working recall system. This system goes hand-in-hand with traceability.
Your recall program is a foundational food safety requirement; you must prepare for when you have a recall, not if you might have a recall.
A good recall program has:
- A team that knows what they need to do, and when they need to do it
- Up-to-date contact lists of who you need to call
- Readily accessible legible records
- The ability to control materials
- A Risk-based decision system
- A review process and process improvement mechanism
- Twice-a-year mock testing
- The discipline and culture to actually do all this effectively
The Team needs a leader who isn’t necessarily the company leader, but needs to be someone with authority and competence to make effective decisions, including when to let the CEO know there is a food safety issue that could involve a recall (right away). The Team needs to have people from the organization who can:
- Act as overall coordinator (team leader)
- Evaluate the issue/manage risks/identify cause
- Update websites, social media pages
- Update 800 number messages
- Rapidly contact affected customers and government officials
- Manage materials within your control – isolate and lock them down
- Manage returning materials – isolate them and lock them down
- Resupply customers with replacement product
- Purchase ingredients/product to replace held product
- Reschedule production to ensure supply of safe product
- Go to retail stores and pull product from shelves
- Rework, repack, destroy product as needed
- Manage inventory including potentially aging inventory
- Meet with employees to address concerns
- Review the process and make changes as needed
Contact lists need to include contacts such as customers, suppliers, Canadian Food Inspection Agency (CFIA), food allergy associations, laboratories with services to help identify the issue including ingredients, equipment, and facilities, and emergency destruction facilities.
When we all worked with paper records, we were given some time to review documents. Because most systems are now electronic, your records should be easy to access within minutes of a call. It may take some time to filter through spreadsheets to pinpoint production, especially for raw material use that could be used in many products in a short period of time. Be prepared to have a team on call over weekends as often CFIA notification happens later in the week. And should you find yourself in a serious recall situation, be prepared to have the team put in a lot of overtime. In addition to ready access, it is important that your documents be legible. This is a really important consideration for looking at computer-based quality and production records so you aren’t trying to figure out someone’s scrawl during an emergency.
You will need a designated place in your facility where you can identify and control product that is on hold. If possible, this should be under lock and key especially when the reason for the recall is a serious risk to health. There are times when this may not be possible, especially when goods are returned from retailers who often don’t bother to check lot codes and simply send back everything flooding your warehouse with product. A part of this exercise is the materials balance; accounting for all of what was used and where it went.
The term “risk-based” gets used a lot these days. Risk-based simply means how likely something bad will happen and if it does, how many people could be affected? For example, low risk could mean unwanted bits of paper in a product that was only sold in a few stores. High risk would be food poisoning organisms in product that is sold to many consumers. Depending on the kind of risk, and the cause of the risk, you may decide to repackage, rework, or destroy your product. Destruction could require using a special disposal service.
Once you have managed to capture all of the affected product, and are back to normal supply levels of good product, you still have to review what you did and identify the cause of the failure, how you fixed the failure, demonstrate that the fix is working, and update your recall procedure if you noticed activities that could have gone better. This is called “closing the loop” and is an extremely important part of a recall.
Most food safety programs require at least one mock recall a year. That is simply not enough. You should conduct at least two per year to ensure the team leader knows how to access information and generate reports. At least one mock recall should look at a raw material, and at least one recall should look at a finished product. One of those recalls should include the entire team to remind them of their roles during a recall. Just doing a materials balance is simply not enough. Many food companies consider this materials balance to be enough to demonstrate their recall process works; It isn’t.
There is no question; managing a recall program is a lot of work. But having an effective one in place saves lives and can save your business. Be sure that your staff understand the essential need to do this, and to do it right.
Still not sure? Reach out to Food Safety at Chemical Compliance for help refining your recall procedure.
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