This article details the requirement for incidents, emergency situations, recalls and withdrawals. The following information complies with:

BRCGS Food Safety Issue 8 3.11 Management of incidents, product withdrawal and product recall
BRCGS Packaging Issue 6 3.13 Management of product withdrawals, incidents and product recalls
BRCGS Agents & Brokers Issue 2 3.11 Management of incidents, product withdrawal and product recall
Storage & Distribution Issue 4 3.7 Management of product withdrawal and product recall
3.8 Incident management and business continuity
5.2.7 Distribution incidents
FSSC22000 Version 5.1 ISO22,000: 8.4 Emergency preparedness and response, 8.9.5 Withdrawal/recall
IFS Food Version 7 5.9 Management of incidents, product withdrawal, product recall
SQF Edition 9 2.6.3 Product Withdrawal and Recall
2.6.4 Crisis Management Planning

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What’s the difference between an incident, emergency situation, recall and withdrawal?

It’s important that you define each of these, so that you apply the correct procedure at the right time. You’ll need to also be able to explain this clearly to your incident team and the relevant elements to those who handle product.

So, let’s go through each one individually.

Incidents

The first thing to be clear about is the difference between an incident and a non-conforming product. When do you apply each one? The best way to think of this is:

A non-conforming product is any product that doesn’t meet the specification. This means a non-conforming product is a physical thing.

An incident isn’t a physical thing, but a reaction to something that’s happened. Treating something as an incident, is a way of acknowledging that something has happened that shouldn’t have and making sure that it’s contained as much as is possible to minimise the impact.

That means, that a non-conforming product can be treated as an incident, if it’s deemed necessary. Or it could just be treated as non-conforming product. The important thing to know, is when to apply the incident procedure. And when to do this is up to your site to define, however it’s expected by the Standards to be applied, to at least product which is unsafe and also, when the product could cause a wide scale negative impact.

The incident system can also be applied to emergency situations. Therefore, an incident is a situation where something has gone wrong, that needs handling with urgency – to minimise the risk to product, personnel, the business, the customer and the consumer.

To clarify, this means that the incident system can be used to manage non-conforming product, an emergency situation and a recall or a withdrawal.

Emergency situations

An emergency situation focuses primarily on safety of personnel on site, the facility and the business. It could have an indirect impact on the product, but it wouldn’t begin that way.

Examples of emergency situations are:

  • Flood or drought
  • Tsunami, severe weather events or natural disasters
  • Fire
  • Warfare or civil unrest
  • Computer or communications outage
  • Pandemic
  • Ammonia leak
  • Disruption to site services such as water, electric or gas supply
  • Disruption to contracted services such as transport or storage
  • Disruption to site services such as refrigeration
  • Staff availability or labour strike
  • Malicious contamination
  • Sabotage
  • Cyber security attacks

Contingency plans

A contingency plan is a plan which is agreed in advance, as a way of reacting quickly to an emergency situation.

A recall or withdrawal plan is also a type of contingency plan – as it’s a plan that’s agreed in advance to allow a recall or withdrawal to be implemented quickly.

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Withdrawal

A withdrawal is a process of handling non-conforming product. Withdrawn product would be unsafe or illegal as a minimum – but may also include product that’s not of the right quality, where requested by the customer.

A Withdrawal is a process by which product is removed from the supply-chain, and where product has not yet reached the customer. This means that the product is still within the business’ control, so it can be withdrawn from the supply-chain. Where the product has gone outside of the business’ control, it must be recalled.

Recall

A recall is also a process of handling non-conforming product. As a minimum the Standards expect this to be applied, where the product is unsafe or illegal.

You can define a recall as a process by which a product is removed from the supply-chain and also from sale. This is where there is a distinct difference from a withdrawal. In a withdrawal situation, the product would not have reached the consumer. In a recall situation, consumers have to be advised to take not consume the product and to return it. This is why in a recall situation you would typically see recall notices in shops, online or in newspapers – to protect the consumer.

The aim of the incident system

The main aim of the incident system is to minimise the impact to:

  • Personnel
  • The business and the facility
  • Customers and consumers

The safety of personnel is obviously the first priority in any situation. Therefore, contingency plans to deal with emergency situations which may put personnel at harm are paramount.

Protecting the business and the facility where the product is handled or where personnel work is key to the survival of the business. Also, ensuring that supply to customers is not impacted is important and of course, ensuring that the consumer is not harmed or mislead is critical.

The aim of the incident system

The main aim of the incident system is to minimise the impact to:

  • Personnel
  • The business and the facility
  • Customers and consumers

The safety of personnel is obviously the first priority in any situation. Therefore, contingency plans to deal with emergency situations which may put personnel at harm are paramount.

Protecting the business and the facility where the product is handled or where personnel work is key to the survival of the business. Also, ensuring that supply to customers is not impacted is important and of course, ensuring that the consumer is not harmed or mislead is critical.

Incident system

The incident system is made up of the following elements:

  • Emergency situations
  • Recall and withdrawal plans
  • The incident team

Let’s go through each element.

Emergency situations

The emergency situation element of the incident system must include:

  • Explanation of what an emergency situation is.
  • Identification of the emergency situations that are relevant to the business and site.
  • Development and approval of contingency plans for the identified emergency situations.
  • Testing of the contingency plans.

Recall and withdrawal plans

The recall and withdrawal elements of the incident system must include:

  • Explanation of what a withdrawal and a recall is.
  • Identification of when a withdrawal will be considered and implemented.
  • Identification of when a recall will be considered and implemented.
  • Development and approval of contingency plans for recall and withdrawal, including:
    • How to escalate the problem internally.
    • Communication plans for external parties.
    • How to trace and reconcile affected product.
  • Testing of the withdrawal and recall plans.

The incident team

To ensure that emergency situations, withdrawals and recalls are managed appropriately, there must be an incident team in place, which:

  • Has representatives from all key functions of the business.
  • Is trained.
  • Has set roles and responsibilities.
  • Has set emergency situation, recall and withdrawal procedures to follow.
  • Has an up-to-date contact list to ensure that communication plans can be implemented without delay.
  • Have agreed processes for recording incidents, so that there’s a robust record of what happened and when. This allows a thorough review to take place, following an incident – to identify learnings.
  • Carries out root cause analysis following a recall or withdrawal.
  • Tests the system at least once per year.

The difference between a trace test and a recall test

Testing of the withdrawal and recall system is such an important aspect of making sure that the system works effectively. However, there’s often confusion about what the test should look like. This often means, that a traceability test is offered as recall test.

  • A traceability test: This challenges your traceability procedures.
  • A recall or withdrawal test: This challenges your incident procedures.

Testing the system

Once the plans are in place, it’s important that you make sure that they work.

The withdrawal or recall test most likely will require traceability of the affected product (which is where the confusion comes from), but it’s more than just the traceability. You need to ensure that the process that’s documented in withdrawal and recall procedure, is tested, to ensure that it works. This means you need to get the recall team together, to check if they all know their roles and responsibilities.

  • Do they know the procedure that they must follow?
  • Do they know where to find contact details?
  • Do the contact details you have, actually work?

A recall test should include calling the phone numbers or using the email addresses that have you’ve specified to make sure you can get through. Does the person at the other end also know what to do? Just make sure you make it clear to them though, that this is a test!

You can carry out a recall and traceability test at the same time. Just make sure that you write them up separately, with a summary for each. One summary assessing the test against the traceability procedure and the other summary assessing the test against the incident procedure.

Top tip – once you’ve carried out your test, print out the information and then using a marker, block out any specific customer or brand details. This way you can use this test to show multiple customers, without having to do a test for each specific brand.

Once the test summary is complete, this should produce a list of things that didn’t quite work right. Use this to make improvements to your procedure.

If you’ve got any questions or anything you can add to this article, to help your fellow techies please do so, by adding it to the comments box below.

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