Development of a Recall Plan

Chapter 10
DEVELOPMENT OF A RECALL PLAN
What Is a Recall? 1.0
1.1 When is a Recall Necessary?
1.2 What is the Facilitys Role and Responsibility?
tRaceabIlIty the backboNe oF Recall 2.0
2.1 What traceability is and Does
2.2 traceability and the Production team
2.3 linking Information throughout the chain
2.4 Defning traceability Policies
Recall PRocess 3.0
3.1 Visualizing the Recall Process
3.2 how to Develop a Recall Plan
stoPPINg DIstRIbutIoN aND coNtRollINg PRoDuct 4.0
WIthIN the FacIlIty
4.1 communication Plan
checkINg the eFFectIVeNess oF commuNIcatIoNs 5.0
5.1 mock Recall
customeR comPlaINt FIles 6.0
6.1 Recording complaints
6.2 Investigating complaints
6.3 corrective actions
6.4 Illness or Injury complaints
Recall FoRm temPlates 7.0
souRces oF INFoRmatIoN 8.0
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Development of a Recall Plan
1.0 WHAT IS A RECALL?
Recall is the process of quick and effcient removal of questionable food
from the supply chain and reaching consumers.
All food recalls have the following aims:
1. Stopping the delivery and sale of the product(s) in question;
2. Informing the appropriate regulatory agencies, such as the
Canadian Food Inspection Agency (CFIA); and
3. Timely removal of the product from the marketplace.
The manufacturer has fnal responsibility for removing products of
concern from the marketplace. Manufacturers must remove such
products before they cause damage or injury. With a good system for
traceability or tracking and a carefully prepared action plan, a recall is
likely to be successful. It may also cost the facility less money.
1.1 When is a Recall Necessary?
Any food safety emergency can trigger a recall. Examples include:
Willful or intentional product contamination;
Human error (including failure of the prerequisite programs);
Mislabeling;
Industrial accidents;
Pesticide contamination;
Foodborne illness outbreak;
Packaging defects; and
Real or threatened product tampering.
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Development of a Recall Plan
There are a number of sources to use to check these concerns. Sources
may vary as to their usefulness at fully understanding the problem.
Sources include:
Consumer Complaints Consumer complaints can be sketchy
or unclear. They may not provide much detail. Always ask those
making the complaint for specifc information including the
product code, dates, where they bought the product, etc.
Distributor or Retailer Complaint Often these complaints are
just as unclear as consumer complaints. Distributors or retailers
usually tell the facility about a concern when they see repeated
complaints about the company or products.
Suppliers Suppliers may fnd something wrong in their own
products. A suppliers internal inspections may lead them to
recall their own products throughout the supply chain.
Internal Inspections Deviations that breach critical control
points, or prerequisite programs, can reveal products that dont
meet standards. End-product testing may also alert facilities to
problems.
Government Inspectors or Agencies The Canadian Food
Inspection Agency (CFIA) carries out numerous food safety
projects and inspections every year. Problems may be found
through random testing, inspections or investigation of
consumer complaints.
Health Authority Illness Investigations Alberta Health and
Wellness documents all outbreaks of foodborne illness. If they
are able to track outbreaks to a specifc product or lot number,
this information can be used to trigger a recall.
Tampering Threats No matter what the source of a tampering
threat, always track this information completely so the facility
can confrm possible affected products.
No matter where the information comes from, take any complaint that
involves a health hazard seriously. Check it immediately.
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Development of a Recall Plan
1.2 What is the Facilitys Role and Responsibility?
Product recalls are a shared responsibility. Industry, government, and
consumers all have roles to play to ensure the rapid, effcient recall of
unacceptable product.
However, it is the responsibility of the facility to ensure product safety.
If the potential of a food safety hazard exists, it is the facilitys duty to
work with the CFIA. This is true even if the processor is not a federally
registered facility.
Tell the CFIA immediately if the facility believes their products may
put consumers at risk. This includes products the facility has made,
processed or sold. Telling the CFIA immediately allows for a quick,
effcient and thorough recall.
Facilities are generally responsible for:
Suggesting the scope or size of the recall;
Preparing and giving out all communications; and
Deciding what to do with the recalled product.
Be prepared to supply the necessary regulatory agencies (CFIA,
regional health authority, or Alberta Agriculture and Food) with the
following information:
A detailed description of the problem;
The name, brand, size and lot codes affected;
Details of complaints received and any reported illness;
Where the product has been distributed or shipped (locally,
provincially, nationally, or internationally);
When the product was distributed;
Example label(s) of the product(s) in question;
The total amount produced and distributed;
The name, phone number or other contact information (email,
cell number) of the facilitys after hours representative.
Sometimes the media
(TV, radio, newsprint)
communicates to
consumers the need
to recall a product.
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Development of a Recall Plan
The more detailed and specifc this information is, the better. The CFIA
may need this information to develop a complete risk management plan
for a recall.
Role of Government Agencies
The Canadian Food Inspection Agency deals with all product
recalls, along with help from Health Canada (providing health risk
assessments). This falls under the Canadian Food and Drug Act and
Regulations.
The CFIA may take the lead role in investigating and coordinating food
safety emergency responses, or it may choose to have the facility keep
them fully informed. Regional health authorities or provincial inspectors
may also take part in the recall process. This will depend on the
situation. All these regulatory agencies are available to help the facility,
for investigations and recall activities.
2.0 TRACEAbIlITy THE bACkbONE OF RECAll
Traceability is the backbone of any quick and effcient recall. Using
recorded information to trace a food item is absolutely necessary. This
helps to decide where the product is in the supply chain.
Recorded information to trace includes the food items:
History
Application
Use
location
being able to track a food item forward or backward through the supply
chain can help control costs by reducing the amount of product recalled
or destroyed.
Food safety and traceability are both very important issues for
governments and industry. Numerous programs to introduce tracking
and tracing methods in the food supply chain are underway worldwide.
Traceability and Product Tracing are both used to describe such
procedures. Since traceability is most common, that is how it will be
referred to in this chapter.
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Development of a Recall Plan
It is impossible to give an exact cost for setting up a traceability
system. This depends on the technology used. It also depends on
the information recorded and what is involved in making the product.
location, customer base and the length of supply chain also affect cost.
2.1 What Traceability is and Does
Generally, traceability systems are record keeping procedures. They
show the route a raw material took from the supplier. This includes
the suppliers steps to produce the product. It also includes the supply
chain from distributors or customers, to consumers.
Any traceability system includes:
Identifcation of units / batches of all raw materials;
Identifcation of units / batches of all fnished products;
Information about when and where the product(s) were used,
transported or sold; and
A complete system to link this information.
Note that trade items are tracked routinely for availability, inventory
management and logistical purposes.
Traceability is a reactive or after the fact food safety tool. It lets
manufacturers and agencies follow the path of a unit and/or lot of
products downstream. It tracks these throughout the supply chain,
as they move between different companies or customers.
In order for it to be effective, a traceability system must identify
where a particular supply chain unit came from. Check records held
by previous owners in the supply chain. Units are usually traced for
purposes such as recall and complaints.
See Form F.18: Supplier/Customer Contact List.
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Development of a Recall Plan


A traceability systems goal is to:
Manage risks related to plant/animal health issues
(e.g. bSE, genetically modifed materials);
Promote informed consumer choice by offering label information
on product quality and ingredient history;
Create trust in the marketplace with fair trade practices
(e.g. show that organic products really are organic); and
Improve product quality and processes (e.g. better inventory
tracking systems).
Can-Trace identies industry requirements for a national
whole-chain food tracking and tracing standard. Can-Traces
goal is to develop a standard to set up traceability based on
international standards. Its a voluntary program developed by
Canadian industry. To help the facility develop programs,
check out Can-Traces resources (Traceability Evaluation
Tool), standards (Canadian Food Traceability Data Standard)
and other materials (Can-Trace News, press clippings, and
more) at www.can-trace.org.
2.2 Traceability and the Production Team
The main responsibility for traceability falls on the facilitys
manufacturing team.
Manufacturing happens when raw materials are blended, formed and
processed. Remember, each raw material in a product has a history.
Tracking lets the manufacturer understand how this history affects the
product.
However, the manufacturing team does not work alone. Traceability
requires a collaborative effort by the whole production team. Other key
players may include:
Research and Development These staff members are the
facilitys gatekeepers. They are responsible for fnding out how
good suppliers are at tracing their own product. They can help shed
light on the suppliers tracking systems before raw materials enter
the facility.

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Development of a Recall Plan
Purchasing and Receiving These staff members must
understand the importance of traceability information to a facility.
Its their job to make sure this information is collected upfront,
before materials enter production.
IT or Management The facilitys IT or management need
documentation systems to internally track ingredients. They will
coordinate these systems with suppliers so that the operations
information needs are met. Its important that the facility can easily
get hold of this information and understand it.
Operations Staff These staff members create the link between
raw ingredients and fnished products. They will record information
to trace materials through the production process. They must
understand the importance of this information and know where to
fnd it.
Shipping Staff Shipping staff are responsible for creating the
link between product information and the customers. They need
to understand the importance of recording production dates for all
materials shipped. These staff members make up the last step in
the production chain.
Train all key staff on traceability. The right information in the tracking
system upfront helps create positive end results.
2.3 Linking Information Throughout the Chain
Traceability requires not only getting information but also using this
information.
If a food safety issue is caused by raw materials, traceability back to
the supplier increases chances of correcting the problem. It also helps
prevent this problem from happening again.
Track ingredients throughout the production process:
When an ingredient enters production, record its lot number;
and
link it to a formula or to production information.
See Form F.13: Raw Material Input.

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Development of a Recall Plan
Give each production run an in-house lot number. This lot number can
carry information such as:
Expiry date;
best before date;
Job or work order number; and
Other useful or important information.
A good system will track every movement. It will track not only the
products movement, but also the movement of every part or ingredient
in the product.
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Development of a Recall Plan
Figure 1: This diagram shows how information is linked within an in-house
traceability system. It shows the ow from raw materials (at the top) to
nished product (at the bottom).
Bulk Goods
Previous Volume of Tank
Recorded, Quantity,
Verified, Delivery Date
Recorded, Supplier Name
Recorded
Recipe / Formula
Work Order Number,
Date of Production
Product
Batch ID or Lot Number,
Best Before Date,
Amount Produced
Packaging Materials
Quality Inspected, Order
Number Recorded, Lot
Number Recorded,
Supplier Name Recorded,
Date Received Recorded
Incoming Materials
Quality Inspected, Order
Number Recorded, Lot
Number Recorded,
Supplier Name Recorded,
Date Received Recorded
Packaging Materials
Amount, Lot Number
Bulk Ingredients
Bulk Tank Number
Recorded, Amount,
Date of Production
Other Ingredients
Name of Ingredient,
Amount, and Lot Number
Recorded
Sub-recipe Components
Amount, In-House ID
Pallet
Barcode, Lot Number
Date of Production
Premixed Ingredients
Name of Ingredient,
Amount and Lot Number
Recorded In-House ID
Assigned
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Development of a Recall Plan
2.4 Defning Traceability Policies
Most confusion in developing traceability systems is about defning the
right unit size. Unit size includes:
batch
Individual container
box of containers
Volume of product
Often unit size is set according to how a particular process is managed.
Each manufacturer must develop its own traceability policies.
Here are some key areas where decisions or policies must be
developed:
Continuous and batch Processing Processors must be able to
safely separate and identify batches.
Handling of bulk Products These products tend to be mixed
with earlier deliveries. So even when they come with clear batch
identifcation, forward traceability may not be possible.
Rework Just because rework is traceable does not reduce the
chances of contamination. Contaminants can be spread over
large amounts of production and over long periods of time. Any
rework can seriously infuence a product recall.
Water Used for Processing Water must be potable and water
source traceable.
Each of these key processing areas must be addressed.
The more key information products carry with them, the better the
chances of fnding and removing them from the marketplace swiftly.
Ideally, the facility wants traceability procedures that ensure the
greatest safety for the product at the least cost to the operation.
GS1 Canada is a not-for-prot, industry led association.
It develops, promotes and maintains global standards. It does
so for the identication of goods, services, locations and
related e-commerce communication. Check out the GS1
Canada website (www.GS1ca.org) to investigate standards,
including the Canadian Food Traceability Data Standard.
There are also other materials and services available to help a
facility develop traceability programs.
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Development of a Recall Plan
3.0 RECALL PROCESS
The steps in a recall are usually the same for all products.
For any recall, the facility must:
1. Identify the concern or problem;
2. Assemble the recall team and put into action the recall plan
(Steps 3 - 11);
3. Stop distribution and isolate the product(s);
4. Start a log of activities;
5. Contact the appropriate regulatory agencies, such as the
Canadian Food Inspection Agency (CFIA);
6. Assess hazards and decide on a recall plan;
7. Communicate;
8. Identify, locate and retrieve the affected product(s);
9. Determine how well the recall is working;
10. Get rid of the recalled product(s); and
11. Fix the cause of the recall.
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Development of a Recall Plan
3.1 Visualizing the Recall Process
Recall Step by Step
1. Identify the concern.
2. Assemble recall team
and put recall plan
into action.
3. Stop distribution and
isolate product.
4. Start a log of activities.
5. Contact the appropriate
regulatory agencies,
such as CFIA.
6. Assess hazard and
determine recall strategy.
7. Communicate.
8. Identify locate
and retrieve.
9. Determine effectiveness.
Nature of problem (type of
hazard and risk).
Results of any tests
or investigations on products
connected with the concern.
Identify the potential
problem and assess whether
an actual risk to food safety
exists.
Decide if more
information or further testing
is needed to make the final
decision.
Decide the size of the recall
and whether other products
may be affected.
Corrective actions to prevent
the cause of the recall.
What possible
solutions are there
for the problem?
10. Dispose of affected
product.
How did the
problem happen?
Is the source of
the problem within
your facility or can
it be traced to a
specific raw
material?
Recondition. Rework. Destroy and
Dispose.
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Development of a Recall Plan
Step 1 Identify the concern or problem.
There are a number of situations that can lead to recalls. Some cause
bigger problems than others. However, all such situations can threaten
consumers in some way.
The following are possible triggers of a recall:
Allergens;
Communicable diseases (e.g. E. coli, Salmonella, listeria);
Foreign materials that are not part of the regular food
manufacturing process;
Damaged packaging (e.g. broken seals, faulty seams, etc);
Notifcations from suppliers;
Tampering or tampering threats; and
Undeclared or unintended ingredients.
The following information is important to help identify and assess each
recall:
Type of hazard;
Type of risk; and
Test results or investigations on products relating to the cause
for the concern.
See Form F.16: Recall Hazard Assessment Form.
Step 2 Assemble the recall team and put the recall
plan into action.
Immediately assemble the facilitys recall team. Everyone has a role
with the process. The sooner the team is assembled the smoother the
process can fow.
Put into action the facilitys recall plan ensure that all the necessary
activities are being performed. Document all activities.
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Development of a Recall Plan
Step 3 Stop distribution and isolate the product
within the facility.
As soon as the facility becomes aware of a problem, immediately stop
all further production and/or distribution of the product. This will help
to narrow down the problem. label any suspect product as ON HOlD.
keep this label until its known whether its safe or connected with the
problem.
The size of a recall will vary from small qualities to large amounts of
product. A good product coding system and traceability program makes
it easier to narrow down affected product. The easier it is to narrow
down the problem, product loss and costs are minimized.
Step 4 Start a log of the activities.
Record keeping helps the manufacturer prove due diligence. For food
recalls, record keeping is particularly important. Record all actions,
including decisions and reasons for them. At least one member of the
recall team should be named as record keeper. That person should
keep an accurate diary of all activities connected with the recall.
See Form F.15: Recall Activities Log.
Step 5 Contact the appropriate regulatory agency.
Communication is very important and it starts within the plant. Once
the -?- are aware of the situation and have set aside the recalled
product within the facility, broaden communication to include the
regulatory agencies.
First, contact the Canadian Food Inspection Agency (CFIA) to ensure
that the action or decision is correct. The CFIA staff can help with
investigations. They should be notifed of all food related health and
safety actions taken on a recall, or on a possible recall. Each region in
Canada has a CFIA Recall Coordinator who can reach the right CFIA
staff.
See Form F.1: Authority Recall Information Form.
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Development of a Recall Plan
Step 6 Consider the hazard and decide on the recall plan.
Once the CFIA has been contacted, consider the hazard of concern and
decide on corrective actions. If the CFIA becomes involved, the Offce
of Food Safety and Recall (OFSR) will decide the recall classifcation for
the situation. However, the facility, along with the CFIA representative
(if one is assigned), is responsible for doing an initial assessment.
This initial assessment will:
Identify the potential problem and decide whether there is an
actual risk to food safety;
Decide whether more information or further testing is needed to
make the fnal decision; and
Determine the size of the recall and whether other products are
affected.
The OFSR uses the information from this initial assessment and
gives the recall a risk classifcation if necessary. Depending on the
classifcation or level of recall, the CFIA has required actions. The CFIA
representative will explain these requirements and communicate the
next steps of the recall process.
See Form F.16: Recall Hazard Assessment Form.
Step 7 Communicate.
The key to any successful recall is communication. Depending on
the class of recall, the facility may have to communicate not only
with customers, but also with media. From the start, make sure this
communication is truthful and accurate. Make it clear and to the point.
Different situations require different levels of detail.
The CFIA has developed communication guidelines to help
the facility. These are found on the CFIA website: www.
inspection.gc.ca/english/fssa/recarapp/rap/mgguide.shtml.
See Form F.10: Notice of Recall.
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Development of a Recall Plan
The facility is responsible for notifying all customers or accounts.
Notify anyone that may have received the affected product.
Prepare a written notice with all necessary related information.
Before handing out this notice, the CFIA may need to approve a draft.
As part of communications, always ask customers to confrm that they
received the notice. Ask customers also to confrm they have taken
action.
Follow up with customers and make sure they received the notifcation
if the facility does not receive an answer. keep ongoing records of all
these activities.
See Form F.2: Communications Log.
Step 8: Identify, locate and retrieve.
Once all customers have been contacted, develop a plan for recovering
and disposing of affected product.
Just as its important to keep track of amounts manufactured and
shipped, it is also very important to keep records of all returned
product. This gives the facility a cross-reference that can reveal how
well the recall is working.
See Form F.12: Production Numbers Record, and Form F.7:
Defective, Suspect and Recalled Product Receiving Form.
Step 9: Determine the effectiveness of the recall.
The frst step in assessing a recalls effectiveness is to make sure
communication is working. The CFIA will also check up on how well
the facilitys recall communication is working and will do spot checks
with customers. They will fnd out whether notifcation was received.
They will also check on whether product is still available for sale and,
if so, why.
If the CFIA has not become involved, its a good idea for the recall team
to undertake these activities.
See Form F.8: Effectiveness Questionnaire.
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Development of a Recall Plan
The second step in assessing a recalls effectiveness is accounting for all
affected product. Require customers to document how many units they
had at the time of receiving the recall notice. This will provide the recall
team with numbers to compare against production fgures.
Depending on how much time passed between product distribution and
product recall, some recalled product may have been sold. Therefore, it
may not be possible to get all the affected product back.
Examine the seriousness of the situation. Examine how much of the
affected product is not accounted for. The facility may have to issue a
public warning about the product.
See Form F.11: Product Reconciliation.
Step 10: Dispose of affected product and put in place
corrective actions.
When all of the related products have been returned, decide on how to
deal with affected product. There are three options available:
Rework
Recondition
Destruction and disposal
The CFIA or another appropriate regulatory agency should frst approve
any decision regarding recalled product disposal. Use the Activities log
to record the action taken for each product.
See Form F.15: Recall Activities Log.
Step 11 Fix the cause of the recall.
If it has not already been done, determine the cause of the recall
and decide on a solution. To show due diligence, the manufacturer
is responsible for ensuring that all reasonable steps have been taken
to prevent similar recalls in future.
Depending on the cause of the recall, the CFIA may return to the
facility later to check on corrective actions and to see if they are
working.
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Development of a Recall Plan
3.2 How to Develop a Recall Plan
Once the recall process is understood set up a plan that prepares the
facility in case a product recall is needed. Put this recall plan in writing.
The plan must show how a facility will make sure that unsafe product is
recalled quickly and effectively.
The recall plan must have procedures and policies to be followed in
regard to:
Raw material tracking throughout the production process;
Product coding;
Customer complaint fles;
Situation analysis and ways of informing relevant government
agencies;
Stopping distribution of products within the facility;
Distribution records and distribution record systems;
How to inform customers, and public (if necessary) about the
recall; and
Roles of recall team members.
Raw Material Tracking
Recalls can be started in various ways.
Ask the following questions:
Is the recall team prepared to act upon a recall by one of the
raw material suppliers?
If an investigation of a complaint fnds a problem with one of
the raw materials, can the recall team decide which products
may be affected?
Can the recall team follow raw materials throughout the
production process to know what products are affected and
which are not?
As explained, traceability is the backbone of the recall process. With a
good traceability program in place, it will be easy to narrow down what
needs to be done during any recall. It also may help reduce related
costs.
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Development of a Recall Plan
Every facility has a different way to record the use of raw materials.
Some facilities make it part of their current production records. Others
have separate documentation forms for raw material use.
At some facilities, production employees record the information, while
at others it is the job of quality assurance staff. How the facility tracks
raw materials will depend on staff levels, workloads and the amount of
information to track.
Figure 2: Raw Material Input Form
AHA! Resource Manual
The Agricultural Policy Framework (APF) A FEDERAL PROVINCIAL TERRITORIAL INITIATIVE
F.13 Raw Material Input
Recall Program: RawMaterial Input Page 1 of 1
Issue Date:
Developed by: Date last revised:
Authorized by: Date authorized:
Name of Employee:
Product Produced: Production Line:
Date:
Shift: am/pm Order Number:
Ingredient Time Used Lot # Time Used Lot # Time Used Lot #
REWORK
Codes Veried By:
Time Veried: am/pm
Comments (if Applicable)




To be completed by: Production or Quality Assurance staff
Purpose: To track ingredient usage throughout the
production process
On-site verication done by: Date: Deviations/comments:
Record verication done by: Date: Deviations/comments:
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Development of a Recall Plan
Product Coding
All products should be coded correctly and easy to understand.
The identifed recall team member will use this information to tell
customers what products are associated with any recall activities. Any
recognizable method of coding is acceptable. letters are often used to
single out the month a product was packed (e.g. Jan, Feb, etc.).
Correct record keeping of these codes lets the recall team trace the
cause of consumer complaints. It also helps control distribution and
inventory. It ensures product rotation, and if necessary, helps in
carrying out a recall.
Record an explanation of the product coding system within the recall
plan. For example, defne what letters are used to signify the month,
and what order the information is being recorded in (e.g. month/ day/
year, day/month/year, etc.).
HOW SHOULD I CODE MY PRODUCT?
Since it should be possible to identify the product by the year and
day it was packed, Best Before dates make sense for product
coding. They allow for ease in tracing back the product to the exact
date of production. If the facility decides to use this type of coding,
it is also important to have some form of batch coding. This helps
to identify between several batches processed on the same day. If
more than one processing facility is involved, each facility must be
shown. Be sure to code all cases and individual containers so they
can be read easily. And remember that whatever code is used, the
facility will need to be able to explain it to both the customers and/
or regulatory agencies.
Julian dates are
three digit codes
used to show the
manufacture date.
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Development of a Recall Plan
4.0 Stopping Distribution and Controlling
Products within the Facility
It is in a facilitys best interest to immediately hold back all affected
recalled products that are still in its control. They should also prevent
any further distribution of this product.
This is most easily accomplished by giving one member of the recall
team responsibility for conducting an in-house stock assessment.
Ensure they isolate any stock that may be related to the problem.
The most effcient way to isolate stock is to identify the product(s)
through signs or labeling. These should indicate clearly that the product
is On Hold.
When labeling product this way, it is important to maintain control. The
sign or label should have the following information:
On Hold marked clearly;
Date that the action was taken;
The initials or name of the person placing the product on hold;
and
Statement that no product is to be disposed of without
clearance from the recall team or management.
When the problem and affected lot numbers have been found, develop
a plan for recovering this product from distribution. keep accurate
records to help limit the recall and to help produce information
accurately and quickly.
The record system should allow for creating a distribution list. This list
should give both the specifc product codes and lot codes.
See Form F.5: Distribution Status Record Sales, and Form
F.6: Distribution Status Record Shipping.
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Development of a Recall Plan
The distribution list should include:
Name of customer and address (including city and province);
Type of account (e.g. manufacturer, distributor, retailer,
restaurant, etc.);
Product name and lot code;
Primary contact at the account;
Telephone number, and other contact information
(email, fax, after-hours phone number); and
Amount of product shipped to the customer.
This information could be gathered from Form b.11 - Shipping
Record and Form F.18 - Customer Contact List.
However, the identifed recall team member may need to reference
other documents to ensure all effected product is accounted for and
customers are notifed.
For these records to help in a recall, make sure those responsible for
the information have enough training. They must understand why the
information is important and why it needs to be recorded.
4.1 Communication Plan
The recall communication system can be set up in various ways.
Whatever method is used, be sure to control all information released.
Most companies control information by using communication templates
or guidelines. This helps to ensure that any written communication is
clear and concise. It also shows the company is concerned.
If a recall involves a health risk, include a defnition of this health risk
in public communications or press releases. Also include some form of
medical explanation. Provide some background on the situation. In this
way the media are less likely to defne the problem. Theyll also be less
likely to develop the information on their own.
Templates or guidelines for recall communication are available
on the CFIA website (www.inspection.gc.ca/english/fssa/
recarapp/recarappe.shtml#rp).
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Development of a Recall Plan
keep in mind that different levels of information are required for
different groups. Different forms of communication should be used
when dealing with:
CFIA
Retailers and distributors
Media
Consumers
The facility is responsible for immediately notifying all accounts
(customers or distributors) that may have received recalled product(s).
5.0 CHECkING THE EFFECTIVENESS
OF COMMUNICATIONS
If the CFIA becomes involved it will check how well the facilitys recall
system is working. It will do so by random surveys of the customers.
This helps the CFIA confrm that all affected product(s) are removed
from the marketplace.
Where the CFIA decides that the recall efforts are not good enough, the
recall may have to be repeated.
If the CFIA has not become involved, its a good idea for the facility to
do an internal or in-house assessment of the communication. This is
most easily accomplished by using recall effectiveness checks. These
checks involve phoning customers who may have received the affected
product(s). Check to fnd out whether they received notice, removed
the product from sale and that they understand the actions requested.
See Form F.8: Recall Effectiveness Check Questionnaire.
In some situations
companies use
communication rms.
This helps to remove
some of the work
associated with recall
communication.
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Development of a Recall Plan
5.1 Mock Recall
The purpose of a mock or trial recall is to test how well the written
recall procedures work. Every time there is a mock recall, the facility
will learn a little more. A drill lets the facility adjust the plan before
there is a real recall. The middle of an actual recall is not the time to
test a recall plan. At this time the recall management team will likely be
too busy with the actual recall.
A mock recall should be able to answer the following questions:
Does the facilitys system run smoothly?
How easily can the facility trace and recover the recall products?
Can the facility look at the lot identifcation records and fnd out
what ingredients the recalled products have in common?
Does the plan have the necessary information to work during
extreme situations (e.g. if management is not available)?
Does the plan let the facility recover and account for all affected
products with the help of production numbers?
Is the record keeping good enough to show where affected
products have been shipped?
Every time the facility runs a mock recall, it will likely need to fne tune
the system. Almost all companies have to adjust their recall system
several times.
Scenarios
When testing the recall system, consider using these scenarios:
Test the system forward from the raw ingredient level.
Example: Our frm received a phone call from Supplier X telling us that
ingredient AbC, lot number XXX, has been contaminated. All products
related with this ingredient should be pulled from the marketplace
immediately.
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Development of a Recall Plan
Test the system backwards from the nished product.
Example: Our frm recently investigated a complaint. We found that
product RQP in the XX-gram-size packages was unsafe. It should be
removed from the marketplace immediately.
Test the system internally.
Example: We recently received notifcation from our supplier that there
may be a problem with ingredient AbC, lot number XXX. The supplier
has asked us to put all associated products and ingredients not already
distributed on hold until further notice.
If the facility fnds shortcomings in the system, adjust the process.
At the end of each mock recall, let the recall committee suggest ways
for improvement. Make the results of the mock recall available to all
staff.
Record Keeping
As with an actual recall, maintain records during the entire mock recall
process. These should include:
All related recall records;
A description of the test scenario;
The date of the test;
Problems found during the test; and
Actions needed to correct each problem found (e.g. changes to
recall plan, training, etc.).
See Form F.9: Mock Recall Record.

As with the recall plan, the facility should provide a procedure and
documentation plan for mock recalls.
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Development of a Recall Plan
6.0 CUSTOMER COMPlAINT FIlES
Customer complaint fles are the most important part of record
keeping relating to recalls. be absolutely sure to record every customer
complaint received. Investigate the basic cause of the complaint.
Accurate fles of customer complaints let the facility identify trends or
problem products and they help in choosing corrective actions.
The three parts of any customer complaint fle are:
1. Recording the original complaint information;
2. Investigating the complaint and recording of fndings; and
3. Corrective actions taken based on what the investigation found.
6.1 Recording Complaints
For each complaint, record the following information:
Source of complaint and contact details;
Separate quality and food safety issues;
Description of the problem (e.g. illness, allergy, foreign matter,
chemical taste, quality issue);
Details of injury or illness (where applicable);
Whether anyone else or an agency has been contacted (e.g.
CFIA, Public Health);
Product details including product name, package size,
identifying codes; and
Retailer information including store where product was bought
and when.
See Form F.4: Consumer Complaint Form.
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Development of a Recall Plan
6.2 Investigating Complaints
Check into all complaints right away, no matter how small. Have a
trained person in the frm investigate.
The goal of any complaint investigation is to answer the following
questions:
How did the problem happen?
Is the source of the problem within the facility or can it be
traced to a specifc raw material?
Does the problem affect any other products?
What possible solutions are there for the problem?
See Form F.3: Complaint Investigation Form.
6.3 Corrective Actions
Once all the results of the investigation fndings have been written
down, decide on corrective actions. If the complaint relates to a product
recall, contact the CFIA to ensure that the action plan is suitable.
Record the following:
Who approved the decision;
When the decision was approved;
What corrective action was taken for affected products; and
Whether the corrective action fxed the problem.
See Form F.3: Complaint Investigation Form.
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Development of a Recall Plan
6.4 Illness or Injury Complaints
If the facility receives a consumer complaint regarding possible illness
or injury, take the following steps.
1. Direct the customer to the local public health authority or
doctor for medical care. If a connection can be found between
the product and the illness, the health region will forward the
information to the CFIA. Health Link (1-866-408-5465) is the
best resource to help the complainant decide where to report
the incident.
2. Contact the appropriate regulatory agencies such as the CFIA.
These agencies may send a representative to the plant to help
fnd the source of the problem.
Its important that employees be considerate and helpful to anyone
who claims injury or illness. Find out if the person making the claim has
had any medical follow-up. Record all details of the complaint including
where and when the product was bought, lot code, best before date,
how it was prepared, when it was consumed, and with what.
Whatever information the facility can get from the person(s) making
the complaint will help the investigation.
If the facility can fnd some of the product in question (if appropriate),
keep it refrigerated or frozen in case testing is needed. If the facility
has records of test results already on hand, attach a copy to the
complaint record.
Be sure to keep copies of all documents related to the particular
product and code with the complaint record. If necessary, hand it over
to the CFIA or health authorities.
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Development of a Recall Plan
Situation Analysis and Informing Relevant Government
Agencies
The recall team is responsible for assessing the situation and for
coordinating all parts of the product recall. The original assessment
must be done in a timely manner. Find out the following information
immediately:
What is the potential problem and is it a food safety risk?
Is more information needed (e.g. further testing, expert advice)
to make a decision?
Does the product need to be taken off the market while a
complete review is done? Is it an emergency situation?
Notify the CFIA immediately if the facility thinks the products may
be a risk to consumers. The Offce of Food Safety and Recall (OFSR)
determines how serious and what class the recall is.
The CFIA will provide the facility with a link to OFSR to speed up
the process. These agencies have their own procedures for making
decisions. This means the CFIA staff member working with the facility
may not be the person making the fnal decision.
The facility must be able to supply the CFIA with the following
information:
A detailed description of the problem;
The name, brand, size, and lot code(s) affected;
Details of complaints received (especially any reported
illnesses);
The distribution of the product (including customers, dates,
and amounts);
label(s) of the products that may be affected;
Total quantity of product manufactured and distributed; and
The name and number of the facilitys after-hours contact.
This information allows the CFIA to develop a complete and correct risk
management plan.
If there is missing information, keep a record of all the information
thats been asked for. In doing so the facility will be prepared if its
necessary to contact the CFIA again.
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Development of a Recall Plan
7.0 RECALL FORM TEMPLATES
F.1 Authority Recall Information Form
F.2 Communications Log
F.3 Complaint Investigation Form
F.4 Consumer Complaint Form
F.5 Distribution Status Record Sales
F.6 Distribution Status Record Shipping
F.7 Defective, Suspect and Recalled Product Receiving Form
F.8 Effectiveness Check Questionnaire
F.9 Mock Recall Record
F.10 Notice of Recall
F.11 Product Reconciliation
F.12 Production Numbers Record
F.13 Raw Material Input
F.14 Sample Raw Material Input
F.15 Recall Activities Log
F.16 Recall Hazard Assessment Form
F.17 Recall Management Team
F.18 Supplier / Customer Contact list
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Development of a Recall Plan
8.0 SOURCES OF INFORMATION
1. Food Science and Human Nutrition Department, University of Florida,
Gainesville. The Food Recall Manual. http://edis.ifas.uf.edu/pdffles/FS/
FS10800.pdf.
2. kaletun, Gnl and zadali, Ferhan. Understanding the Recall Concept
in the Food Industry. Ohio State University Extension Fact Sheet. http://
ohioline.osu.edu/aex-fact/0251.html.
3. Food Standards Australia New Zealand. Food Industry Recall Protocol
5th Edition (2004). http://www.foodstandards.gov.au/_srcfles/5th%20
FIPR_june04.pdf.
4. Canadian Food Inspection Agency Agriculture and Agri-Food Canada, and
Canadian Council of Grocery Distributors. Supply Chain Food Product
Recall Manual (2003 CFIA).
5. Canadian Food Inspection Agency Food Recalls: Make A Plan And Action
It! Manufacturers Guide (2001).
6. Electronic Commerce Council of Canada Tracking and Tracing of Food
Products in Canada (2003). http://www.can-trace.org/portals/0/docs/
TrackingAndTracingInitiativeWhitePaper.pdf.