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Product withdrawal and recall procedure for GFSI schemes…

In this post, we’re going to look at product withdrawal and recall. Before we go any further, let’s just clarify what we mean by withdrawal and recall, as there is a distinct difference between the two.

Withdrawal: is the process by which a product is removed from the supply chain, and where product has not yet reached the customer.

Recall:   is the process by which a product is removed from the supply chain and where customers are advised to take appropriate action.

So, basically, if the product is still within your control, you can withdraw it.  Where the product has gone outside of your control, it must be recalled.

What the standards say…

All of the GFSI schemes include this requirement, as the clause for serious incident management is clear in the GFSI guidance:

“The standard shall require that the organisation 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.”

The IFS standard adds a little more detail to this and states that a documented and effective procedure must be in place, which provides clear roles and responsibilities of the incident team, key emergency contact details and that the system must be tested at least once per year.

The BRC and SQF code go into more detail.  The requirements of both are essentially the same, with the exception that the BRC writes into this section that they require the site to inform their certification body within 3 working days in the event of a recall. SQF also require an accredited site to inform their certification body in clause iv, but they detail the time frame in Part A of the standard, under section 5.3 Notification of Product Recalls and Regulatory Infringements.  An important point to note is that, the SQF code asks that this notification take place within 24 hours of the event, so they do not allow as much time as BRC.

SQF Code, Level 2, Edition 7.2
BRC Food Safety, Issue 7
2.6.3 Product Withdrawal and Recall (M) 3.11 Management of Incidents, Product Withdrawal and Product Recall
2.6.3.1 The responsibility and methods used to withdraw or recall product shall be documented and implemented.

 

The procedure shall:

  1. Identify those responsible for initiating, managing and investigating a product withdrawal or recall;
  2. Describe the management procedures to be implemented including sources of legal and expert advice;
  3. Outline a communication plan to inform customers, consumers, authorities and other essential bodies in a timely manner appropriate to the nature of the incident.
  4. SQFI and the certification body shall be listed as an essential body and notified in instances of a food safety incident of a public nature, or product recall for any reason.

2.6.3.2 Investigation shall be undertaken to determine the root cause of a withdrawal or recall and details of investigations and any action taken shall be documented.

2.6.3.3 The product withdrawal and recall system shall be reviewed, tested and verified as effective at least annually.

2.6.3.4 Records of all product withdrawals, recalls and mock recalls shall be maintained.

(3.11.1 Emergency planning covered in previous post)

3.11.2 The company shall have a documented product withdrawal and recall procedure.

This shall include as a minimum:

  • Identification of key personnel constituting the recall management team, with clearly identified responsibilities.
  • Guidelines for deciding whether a product needs to be recalled or withdrawn and the records to be maintained.
  • An up-to-date list of key contacts (including out-of-hours contact details) or reference to the location of such a list (e.g. recall management team, emergency services, suppliers, customers, certification body, regulatory authority).
  • A communication plan including the provision of information to customers, consumers and regulatory authorities in a timely manner.
  • Details of external agencies providing advice and support as necessary (e.g. specialist laboratories, regulatory authority and legal expertise).
  • A plan to handle the logistics of product traceability, recovery or disposal of affected product, and stock reconciliation. The procedure shall be capable of being operated at any time.

3.11.3 The product recall and withdrawal procedures shall be tested, at least annually, in a way that ensures their effective operation. Results of the test shall be retained and shall include timings of key activities. The results of the test and of any actual recall shall be used to review the procedure and implement improvements as necessary.

3.11.4 In the event of a product recall, the certification body issuing the current certificate for the site against this Standard shall be informed within 3 working days of the decision to issue a recall.

Summary

If we review the above requirements, we can state that to comply with product withdrawal and recall we must:
  • Have a documented procedure
  • The procedure must be sufficiently detailed to explain the withdrawal and recall process
  • It must detail those, by name, who are on the withdrawal and recall team
  • It must detail roles and responsibilities of those in the team
  • Where external advice will be sort
  • Who is responsible for communicating what and with who, including contact details
  • Actions must be documented and root cause analysis must be used to prevent reoccurrence
  • A documented test must be conducted as least annually

The Test

Testing of the withdrawal and recall system is such an important aspect of making sure that the system works effectively.  In my opinion, this test has been previously misunderstood, both by sites and auditors. I have been on many audits myself where an auditor has requested the site recall test and has been presented with a traceability test, which they accepted.  There is a distinct difference between a traceability test and a recall test.

A traceability test, is a test which challenges your traceability procedures.

A recall test, is a test which challenges your withdrawal and recall procedures.

The withdrawal or recall most likely will require traceability of the affected product (which is where the confusion comes from), but it is more than just the traceability.  You need to ensure that the process that is 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 this phone numbers, or using the email addresses that have been 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!

If you’re clever 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 withdrawal and recall 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 – I really urge you to do this, you will kick yourself that you didn’t, if the worst was to happen and you really needed to instigate a withdrawal or recall.  Better to learn from a test, than the real thing!

In the next couple of posts I’m going to cover some withdrawal and recall scenarios that you can try.  Before you do the scenarios, review your current procedures against the requirements above, to make sure they comply.  That way you can make sure you’re ready to challenge them with the tests! As always, if you have any questions, please put them into the comments box below.
recall plan

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