Product Recall

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Background

The number of food incidents in the UK handled and investigated by the Food Standards Agency numbers over a thousand. Many of these incidents, where there are concerns about the safety of food, have resulted in product recalls or withdrawals to protect consumer's interests.

Reasons for product recall can include:
 incorrect labelling, such as omission of allergy information
 detection of foreign objects such as glass, plastic, wood or insects
 microbiological or toxin contamination, which could cause an outbreak of food poisoning
 detection of unacceptable taste or odour
 defective packaging
 malicious contamination

All food businesses are responsible for the safety of food. Unsafe food is considered to be that which is either injurious to health, or unfit for human consumption. Once suspected or identified it must be effectively withdrawn from sale, or recalled from consumers if already sold.

It is therefore crucial that food businesses are able to identify the businesses from whom they have obtained food, ingredients or food-producing animals, and the businesses they have supplied with products, and be sufficiently organised to be able to produce this information on demand.

Product recall and withdrawal procedures form part of the pre-requisite requirements of a HACCP (Hazard Analysis Critical Control Point) plan, and should be documented with records maintained.

Requirements of a Product Recall Scheme

The following steps are suggested for implementation of a product recall scheme:

 All complaints received by a business that relate to products despatched from the premises are logged on a form detailing the date, contact details, nature of the complaint, and actions taken.

 Depending on the size of the business, an individual or a team of people are designated as being responsible for handling any incidents and making prompt decisions. Each complaint must be assessed for risk to consumers and a decision made as to whether products need to be withdrawn or recalled.

 When it is considered that a product recall may be necessary, food business operators must notify both the local Authority and the Food Standards Agency.

 The police must also be informed if malicious contamination is suspected.

 Batch numbers and destinations of all products leaving the premises on a daily basis en route to further food businesses must be recorded on despatch monitoring forms, so these can be referred to if products need to be recalled.

 Food business customer records must be currently maintained so that contact information can be rapidly made available. Customers must be immediately contacted by telephone and informed of the risk, with instructions whether to return or destroy the products. Access to emergency contact lists should be available for day or night use.

 Where products have already been sold on to consumers, a public recall must be implemented as appropriate, such as by newspaper advertisements, notices at the point of sale, websites or carelines.

 The problem with the product must be identified. The product could be sent for microbiological laboratory tests in cases of deterioration or food poisoning, an analytical laboratory for detection of contaminants, or microscopy analysis to assist in the identification of unknown objects.

 The work procedures at the premises must be immediately reviewed to ensure that every action has been taken to prevent the problem from recurring. This also includes a review of the HACCP plan.

 Once a product recall system is in place, it must be reviewed regularly and tested to see how it actually works, such as how far the traceability extends. It should be demonstrated that, if an incident occurs, the problem be narrowed down to the affected batch or batches.

Implementing a Product Recall System

1. This system has been designed to deal with the unlikely event that a problem arises which, it is considered, poses a health risk to the general public, creating the attendant adverse publicity. It will be where a fault in product produced and/or, sold by you, has been identified by Environmental Health Officers, or by personal observation, in circumstances when a number of customers have reason to complain.

It is considered essential that a system, which may never be used, is put in place to deal with such an eventuality. It is not recommended that you do this when coping with the emergency. Please prepare a list of names and essential telephone numbers which would be required and maintain this in a prominent position within your premises. This list should cover:

 Environmental Health Officers – names, addresses, day, and out of hours
telephone numbers, mobile numbers etc
 Local Press and Radio Stations – names and telephone numbers.
 Police – names and telephone numbers.
 Key Staff Members (what would be known as your Product Recall Team) –
addresses, telephone numbers etc

2. Create a Product Recall Team – who is to manage the media, the telephone for recall customers, the deep clean of your shop, maintain the ongoing business etc. Only you can select members of your staff who will have the ability to deal with specific aspects of such an emergency. In smaller units, one/two persons may have to cover all facets.

When it becomes necessary to order a product recall, speed is essential in dealing with the various steps. We suggest that these might be as follows:

a. Complete Customer Complaint Forms to include:
Customer's name, address and telephone number
Full description of product involved (including Traceability Code if there is one)
When purchased and if receipt held (this enables confirmation of date, time etc)
Nature of complaint
Nature of illness
Has a doctor been called and, if so, what is his diagnosis?
Has anybody been hospitalised due to food poisoning – if so, where?

b. Contact the Federation for advice
(tel: 01738 637472, 0795 784 2299 after hours)

c. Contact Environmental Health Officer – advise them of the problem and invite them to
the shop to discuss the situation. Provide lists of affected customers with names,
addresses, telephone numbers etc

d. Review all HACCP/Traceability Systems and Procedures in place.

e. Agree with EHO if it is a situation which calls for product recall.

Once this has been established, the EHO may wish to send product for analysis to establish the nature of the problem. All Butchers should insist that they keep a sample for their own preferred laboratory to analyse separately. This should be done immediately in conjunction with the EHO, but using an independent analyst. This precaution will provide a major point in your defence in respect of “due diligence”. All other sampled product should be wrapped, labelled and frozen. (Please note that frozen product is not considered satisfactory in the future for comparative analysis).

3. Product Removal procedure – remove any remaining product from the same problem batch throughout the premises and immediately place in wrapping, label and freeze, ensuring that a chilled sample is taken prior to this being completed.

4. Communication to General Public – after discussion, and on the instruction of the EHO, place the following advertisement in a local newspaper.

“ANY CUSTOMER WHO PURCHASED X PRODUCT ON Y (DAY< DATE & TIME) ARE ADVISED NOT TO CONSUME THIS PRODUCT BUT TO RETURN IT TO (NAME OF BUSINESS) FROM WHERE IT WAS PURCHASED FOR A COMPLETE REFUND" Also contact your local radio station, provide them with the facts, as agreed with the EHO, and ask them to advise all listeners who have purchased the suspect product from your shop to return it. You should also place the proper recall notice in your shop window and where it can be easily read by anyone coming into the shop. Remove all other notices from windows and shelves. 5. Staff Advice – in the unlikely event that you are obliged to carry out the above procedure, immediately call all serving staff together, advise them of the nature of the problem and confirm with them what information they can provide to the general public. 6. The Federation would recommend that all members carry out a “dummy run” to ensure that the above procedure operates satisfactorily for them. GENERAL NOTES batch coding – two options to offer

1. Colour Coding: Monday – red, Tuesday – blue, Wednesday – green, Thursday – red, Friday – blue, Saturday – green. This colour coding can be used for product with 3 day shelf life. If you go to fill your shelves on Thursday and red colour coded product from Monday remains, immediate action should be taken to remove this from the counter. This procedure is repeated accordingly on a day by day basis.

2. Number Coding: The week number (1 to 52) followed by the day number (1 to 6), followed by the batch number of product produced in an any particular day e.g. three batches of beef sausages, therefore on a Wednesday the code would be 37 (assuming the 37th week), 3 for Wednesday and 2nd batch of beef sausages code would read 3732.