Product Recall Part 2 — What Is Your Plan?


Product Recall Part 2 — What Is Your Plan?

Thursday, September 03, 2020

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If you fail to plan, you plan to fail is the statement often used to emphasise the importance of being prepared and knowing the strategies that will be used for an eventuality. This is even more applicable in situations of high risk such as a food safety incident where a product needs to be taken from trade.

When looking at your plan, it's important to know the difference in withdrawal versus recall. If the product is in the supply chain but has not yet reached the customer, then removing it is known as withdrawal. Conversely, if the product has reached the customer, then it is a recall. Therefore, if it is within your control it is a withdrawal; outside of your control it is a recall.

Food business operators are required to have a plan in place that is tried and proven on how to recall products. In addition, various food safety management schemes have a requirement that food businesses must have a plan and procedure in place for product recall, including conducting a mock recall.

In fact, the Global Food Safety Initiative (GFSI) stipulates that organisations must establish, implement and maintain an effective incident management procedure which is regularly tested for all products it supplies, and covers planning for product withdrawal and product recall as required.

An important question a food business operator must ask is: What is my recall policy? This should be a simple statement that is clear and concise. The policy should show the authority of the responsible party, how it relates to food safety management system, be communicated throughout the organisation and be reviewed and amended as appropriate.

A recall system must be robust and linked to the food business risk management strategy. The recall procedure must be documented, showing clear roles and responsibilities of the recall team, emergency contact details and how often the recall process is tested. This includes having a communication channel to notify customers, regulators and other interested parties.The steps of a food recall can be looked at as: Identifying and assessing the problem, identifying affected products, notification of interested parties, retrieving and disposal of affected products, monitoring effectiveness, ending the recall and evaluating/reporting on the process.

A recall checklist may include the following:

1. Identify which batch of product is affected

2. Segregate any stock that was not distributed

3. Contact interested parties (regulators, certification body, etc)

4. Identify where the product was distributed

5. Compile a distribution list showing direct customer contact details and where the food product is likely to be sold

6. Contact distributors

7. Inform the public

8. Implement corrective actions

9. Arrange for segregation, storage and disposal of affected stock

10. Monitor effectiveness of the recall

11. Prepare an interim and post-recall report

Food business operators must plan ahead to avoid damages to their brand's reputation and customer base; part of this planning includes testing their business process, workers' ability to respond and procedures utilised through what is commonly referred to as a mock recall. This helps a food business operator to objectively assess effectiveness of response, how decisions are made and how the logistics are performed.

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