Recall Plan and its Procedure

Section 28(1) of FSS Act, 2006 stipulates that If a food business operator considers or has reasons to believe that a food which he has processed, manufactured or distributed is not in compliance with this Act, or the rules or regulations, made thereunder, he shall immediately initiate procedures to withdraw the food in question from the market and consumers indicating reasons for its withdrawal and inform the competent authorities thereof.

Meaning of Recall

Recall can be defined as an action to remove food products from the market at any stage of the food chain, including that possessed by a consumer, which may pose a threat to the public health or food that violate the Act, or the rules or regulations made thereunder.

Recall of food products is in the common interest of the industry, the government and in particular the consumer.

Objectives of the food recall procedure

(1) Ensure removal of food under recall from all stages of the food chain in accordance with section 28 of the Act;

(2) Ensure dissemination of information to concerned consumers and customers; and

(3) Ensure retrieval, destruction or reprocessing of food under recall.

Conducting a recall plan

Step 1: Assemble your recall management team

At the very beginning of the recall, the FBO should initiate the formation of a recall management team and assign the recall duties to each person and should ensure that all members of the recall management team are informed of the decision to conduct a recall and each member knows their responsibilities during the recall.

The team should include people responsible for:

1. Decision making

2. Quality assurance / technical advisory

3. Media communication

4. Complaint investigation

5. Contacting accounts

6. Food Authority Contact

7. Legal Counsel The management team document should contain the following:

RECALL MANAGEMENT TEAM
NAME ALTERNATE PERSON BUSINESS PHONE AFTER HOURS PHONE RESPONSIBILITIES DURING RECALL

Step 2: Inform the authority

Inform the concerned regulatory authority at the earliest opportunity, after an incident is identified that may lead to a recall and should be updated throughout the process. The information should include the following:

  • A detailed description of the nature of the problem
  • The name, brand, size, lot code(s) affected
  • Details of complaints received and any reported illnesses
  • The distribution of the product – local or national
  • When was the product distributed (specific dates)
  • Label(s) of the product(s) which may be recalled
  • The total quantity of products manufactured and distributed
  • The name of your firm’s contact with the authority
  • The name and telephone number(s) for your firm’s after-hours contact

The detailed information is given under Schedule I of FSS (Recall Procedure) Regulations, 2017

Step 3: Identify all products to be recalled

It is the responsibility of FBO to ensure that all products which need to be recalled are identified. In addition to those products directly affected by the problem, the FBO should:

  • Determine if any other codes, brands or sizes of the same product are affected
  • Determine if any other products are affected

Step 4: Detain and segregate products to be recalled which are in your firm’s control

The FBO should ensure that all products to be recalled that are in your firm’s control are not distributed and;

  • Determine the locations of the recalled product(s) e.g. on-site, at the plant, offsite storage
  • Determine the amounts at each location
  • Identify and segregate products to prevent the distribution

Step 5: Prepare and distribute the information of recall;

Informing the Consumer: Depending on the extent of the recall, the company concerned should inform the consumer of the recall at the earliest possible moment.

Information dissemination may take the form of a press release, letter to the concerned parties or paid advertisement in the media. Sufficient telephone hotline service should be made available to deal with enquiries.

Information within the Food Chain: – The FBO shall inform everyone in the food chain from the raw material vendor to the supplier and any other relevant retailer or trade association of the affected food by written communication, phone, e-mail, fax, or a combination of thereof.

The press release, letter or advertisement shall be in the form of ‘Food Recall Notice’ and shall contain the following information, namely: –

  • Name of the Food Business Operator recalling the food;
  • Name of the food, brand name, pack size, batch and code number, date of manufacture, used by date or best before date;
  • The contamination or violation in the food or reason for such recall;
  • “Do not consume message”;
  • Health warning and action;
  • The places or outlets where the food is found;
  • The action to be taken by the consumer;
  • Contact number for queries.

 The FBO must:

  • Complete the press release within two hours after being notified of the recall
  • Submit a draft of the proposed Press Release, if required, to the concerned Authority for approval
  • Arrange for translation of the press release for the concerned region

Step 6: Prepare the distribution list

Keeping accurate distribution records allows limiting the recall to the specific accounts that received the product being recalled. Using the distribution record system, produce a product and lot code specific distribution list which:

  • Identifies the accounts that received the recalled products
  • Lists the accounts names and addresses, contact names and telephone numbers
  • Identifies the type of account e.g., manufacturer, distributor, retailer

Step 7: verify the effectiveness of the recall

  • The food business operator should determine whether the recall is progressing effectively and submit periodic status reports to the concerned authority to inform the progress of the recall. FBO shall submit the periodic recall status report once a week or as otherwise specified by the concerned authority.
  • To conduct an effective recall, the FBO should maintain the food distribution records which include Name and address of suppliers and distributors, date of purchase of raw material, batch code, lot number and complete traceability from Raw material to finished good

Step 8: Control of the recalled product(s)

The product is to be recovered to a central site, or in the case of a widely distributed product, to major recovery sites. The recovered product must be stored in an area that is separated from any other food product. Accurate records are to be kept of the amount of recovered product and the batch codes of the product recovered.

It is the responsibility of the FBO to ensure that recalled products do not re-enter the market.

  • Separate and identify the recalled product(s)
  • Reconcile quantities and monitor returned product(s)
  • Record the recalled product(s) in Recalled Product Records document

Step 9: Decide what to do with the returned product

After recovery, products may be corrected or reprocessed before releasing to the market if it is fit for human consumption. Otherwise, the product is to be destroyed. The action to be taken on the recalled product should be approved by the competent Authority

  • Decide on the action to be taken on the recalled product e.g., correction, re-export, destruction
  • Find out if the Authority wants to witness/verify that the action has been taken
  • Verify that the action has been effective
  • Record the action taken for each product in your Recalled Product Records document

Step 10: fix the cause of the recall

As the manufacturing firm that produced the unsafe product, it is your responsibility for ensuring that all reasonable steps are taken to prevent similar recalls in the future.

  • Put controls in place or revise existing controls to prevent similar problems in the future

Responsibility of the Food Authority

(1) The Food Authority shall guide and supervise the Commissioner of Food Safety of the State or Union Territory in the execution of the Recall Plan and, where necessary, it may assess the relevant reports submitted by the food business operator and give instructions as may be required.

(2) The Food Authority may establish a web-based facility titled ‘Food Recall portal’ on its website with a unique identification number assigned to each recall for monitoring and to provide information to the consumers about such recall.

(3) The Food Authority may also publicise about the recall when it considers that the public need to be alerted about the health hazard depending upon the seriousness of the situation and it shall keep the concerned food business operator(s) aware of the same.

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Disclaimer: The entire contents of this document have been prepared based on relevant provisions and as per the information existing at the time of the preparation. Although care has been taken to ensure the accuracy, completeness, and reliability of the information provided, I assume no responsibility, therefore. Users of this information are expected to refer to the relevant existing provisions of applicable Laws. The user of the information agrees that the information is not professional advice and is subject to change without notice. I assume no responsibility for the consequences of the use of such information. IN NO EVENT SHALL I SHALL BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL OR INCIDENTAL DAMAGE RESULTING FROM, ARISING OUT OF OR IN CONNECTION WITH THE USE OF THE INFORMATION

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