Food Recalls: Make a Plan and Action It!
Retailers' Guide

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Table of Contents

1. Introduction
2. Make a Plan
   • Recall Management Team
   • Complaint File
   • Recall Contact List - CFIA
   • Tracing of Products
   • Recalled Product Records
   • Recall Procedures
   • Testing Your Recall Plan
3. Action Your Recall Plan: Steps to an Effective Recall
   • Introduction
   • Assemble Your Recall Management Team
   • Notify the CFIA
   • Identify All Products to be Recalled
   • Detain & Segregate Products to be Recalled
   • Prepare the Press Release
   • Control of the Returned Product
   • Action Taken for Recalled Product
   • Fix the Cause of the Recall
   • Common Problems with Recalls, Potential Impacts & Recommended Solutions
   • Appendix A: Press Release - Industry Template, Allergens
4. General Reference Information on Recalls
   • Definitions
   • Recall Classifications

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1.0 INTRODUCTION

What is a food recall?

Food manufacturers use many controls to make sure that the products they produce are safe. Sometimes, for many different reasons, a product may be manufactured and sold which may make some people ill or injure them, or is in violation of the legislation. When an unsafe or violative food product has left the control of the manufacturer, it must be removed from the market. This process of removing the product is called a "recall". If your firm has purchased a product which is unsafe or violative and you have sold the product to someone else, you must recall the product. If you choose not to conduct a recall, the Minister of Agriculture may order you to conduct the recall under Section 19 of the Canadian Food Inspection Agency Act. This applies to all retail stores which have sold an unsafe food product.

What is the goal of this guide?

Ask yourself these questions.

"If you needed to remove a product from the store shelves right now, would you be able to do it?"
"Would you be able to remove the product quickly?"
"Would you be able to remove all of the product?"

The goal of this guide is to provide you with an overview of how to develop a recall plan and how to action that plan in the event of a recall. It will assist you in identifying unsafe products which you have received and sold.

Special Circumstances

There are four guides which have been prepared for firms in the food industry.

Retailers' Guide: If your activity is limited to purchasing products and selling them directly to the consumer, then this is the only guide that you will need to follow.

Manufacturers' Guide: If you are manufacturing products at your store, for example, prepared meals for consumers, barbeque chickens, etc. then you will need to refer to the Manufacturers' Guide.

Importers' Guide: If your are importing products directly into the country, then you will need to refer to the Importers' Guide.

Distributors' Guide: If you are selling your products to other retail stores, then you will need to refer to the Distributors' Guide.

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2.0 MAKE A RECALL PLAN

Recalling a product is a planned action. This section of the guide describes how your store can develop a written recall plan prior to having a recall. This will help you remove unsafe or violative product(s) which your store has purchased and sold, from the market quickly and efficiently.

There are seven basic elements which should be included in your recall plan. All of these elements must be included; each element plays a specific role and provides a different benefit to your firm.

1. RECALL MANAGEMENT TEAM

Benefits

When an unsafe food product has been identified it must be removed from the store shelves quickly. Identifying persons in your firm and assigning recall duties to each person will allow you to action your recall plan smoothly. You can be assured that all of the procedures are covered. Also, many recalls happen after regular work hours so you must be prepared to contact people outside of the premises. The list of people who make up your team should be reviewed and updated on a regular basis.

Description

Your team should include people responsible for:

1. Decision making
2. Quality assurance / technical advisory
3. Media communication
4. Complaint investigation
5. Contacting the CFIA
6. Legal Counsel

Your recall management team document should contain the following information:

RECALL MANAGEMENT TEAM

NAME	ALTERNATE PERSON	BUSINESS PHONE	AFTER HOURS PHONE	RESPONSIBILITIES DURING RECALL
Person's name and position in the firm	a replacement individual in the event that the person is not available			the duties of the person during a recall

2. COMPLAINT FILE

Benefits

If you receive a complaint, it is important to record the complaint information, complete an investigation at your store, and refer it to the CFIA. Early action on your part may enable you to stop selling the product until it is determined that the product is safe.

Description

There are three main parts to the complaint file:

1. Recording of the initial complaint information
2. Investigating at the store
3. Action taken for the specific product

Recording of the Initial Complaint Information

The complaint should be recorded by a designated individual(s). It is important to include enough information so that the manufacturer, importer, or distributor of the product can start an investigation of the problem immediately. This may include but is not limited to:

1. Complainant details

• name, address, telephone number (s) of the complainant
• illness or injury involved

2. What is the problem with the product, e.g. chemical taste, allergic reaction, illness, object in the food

3. Product details

• package type and size
• product name
• identifying codes
• date of purchase
• does the complainant have a sample of the product?

4. Has the complaint been referred to anyone else?, e.g. manufacturer, importer, distributor, the Canadian Food Inspection Agency or Public Health

Investigation at the Store

It is important when you receive a complaint to make sure that the problem with the product did not result from activities at your store, for example: the product may have been stored at the incorrect temperature. Investigate the complaint fully. If you determine that the problem was caused by activities at your store, contact the CFIA immediately.

Record in your complaint file:

• the name of the person at your store who investigated the complaint
• date and time of the investigation
• investigation findings
• other products which may be affected by the problem

Complaint Referral

If you determine that the problem was not caused at your store, contact the CFIA immediately.

Record in your complaint file:

• the name of the person at your firm who contacted the manufacturer, importer, distributor or CFIA
• the name of the person contacted at the manufacturing, importing, distributing firm or CFIA
• date and time of the referral

Action Taken

If you have an unsafe or violative product in your store, you are responsible for removing the product from sale immediately and contact the CFIA.

Once you have been notified of a recall or product action by a manufacturer, importer or distributor, you should record:

• what the action is, i.e., recall, no recall
• the manufacturer's, importer's or distributor's instructions of what to do with any of the product that you may have on site

3. RECALL CONTACT LIST - CANADIAN FOOD INSPECTION AGENCY (CFIA) NOTIFICATION

Benefit

If you suspect that you have sold an unsafe food product contact the CFIA immediately. The CFIA staff can assist you with your investigations and should be notified of all food-related health and safety corrective action decisions. Each area in the CFIA has a Recall Coordinator who will assist you in contacting CFIA staff to help you with your investigation and the collection of the information necessary to make the right decision. A list of CFIA Area Recall Coordinators is provided below. Since the list may change, it should be reviewed frequently. This list is available on the CFIA website: www.inspection.gc.ca.

Description

Your CFIA contact list should contain the following information:

• name of the CFIA contact
• contact telephone number
• contact fax number

The current CFIA Area Recall Coordinators can be reached at these telephone numbers from 8h00 to 23h00:

• Atlantic - 506-381-7683
• Quebec - 866-806-4115
• Ontario - 416-665-5049
• Manitoba - 204-797-4501
• Saskatchewan - 306-529-0671
• Alberta - 403-661-7505
• British Columbia - 604-978-1120

4. TRACING OF PRODUCTS

Benefits

Being able to identify which product(s) has to be recalled is a great benefit to your firm. It allows you to limit the scope of the recall and remove the product(s) from sale quickly and accurately. To do this, you must be able to identify who supplied you the product

Description

To limit your recall to a specific product(s) you must:

1. Link the products you have received to each supplier

Receiving Records

All products that you receive should be identified with a specific lot code. You should have a system in place which identifies and records the lot codes of each product you have received from each supplier.

For each supplier you should document:

• the definition of a lot for each product
• how to interpret the lot number (obtained from the supplier)
• the lot numbers for each product you received

5. RECALLED PRODUCT RECORDS

Benefit

For your own protection, keep records of products that you have recalled from your store.

Description

Your recalled product records should contain:

• a description of the product recalled: brand and product name, size, identifying codes
• the amount of product recalled
• the date the product was recalled
• what you did with the product, for example, returned to the supplier

6. RECALL PROCEDURES

Benefit

Several activities may happen simultaneously during a recall. Having a step-by-step recall procedure will ensure that all of the activities are completed. This is the plan that you will action during a recall. A brief description of each of the recommended steps is included below. Further details on the parts of each step and how to action your plan are described in Tab 3 of this guide.

Description

The recommended step by step procedure is as follows:

7. TESTING YOUR RECALL PLAN

Benefit

During a recall, your firm's recall management team will be busy putting your recall plan into action. This is not the time to find out that your recall plan is not working or that the plan does not provide the information you need to remove the unsafe product from the store shelves completely and quickly. Testing your recall plan before you have to do a recall, enables you to identify and correct problems in your plan.

Description

Your recall plan should be tested on a regular basis.

When you test your recall plan, you should record:

• a description of the test scenario, for example: "Our firm received a phone call from Supplier "X" who informed us that product "AA" was contaminated and that the product should be removed from the store shelves immediately"
• the date of the test
• problems you identified during the test
• for each problem you identified during the test, how you changed the recall plan to correct the problem.

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3.0 Action Your Recall Plan - Steps to an Effective Recall

Introduction:

Tab 2 of this guide described how your firm can develop a written recall plan prior to having to conduct a recall. These written elements form the basis for:

• identifying health and safety concerns in your existing food safety systems
• contacting and working with CFIA staff
• assigning recall duties to specific individuals in your firm to ensure that all parts of the recall are covered
• tracing and identifying products which are affected by the problem
• controlling returned product
• testing your written recall plan to ensure that it is efficient and effective.

All of these elements should be developed and documented prior to conducting a recall.

NOTE: As stated in the Introduction, there are four versions of this guide. Before you proceed with this section of the guide, please refer to the list below to ensure that you are using the proper guide for the problem which has been encountered.

Retailers' Guide: If your activity is limited to purchasing products and selling them directly to the consumer, then this is the only guide that you will need to follow.

Manufacturers' Guide: If you are manufacturing products at your store, for example, prepared meals for consumers, barbeque chickens, etc. then you will need to refer to the Manufacturers' Guide.

Importers' Guide: If your are importing products directly into the country, then you will need to refer to the Importers' Guide.

Distributors' Guide: If you are selling your products to other retail stores, then you will need to refer to the Distributors' Guide.

The goal of this section of the guide is to describe, in detail, each of the key steps your firm should take once it has been decided that a recall will be conducted. These recommended steps include the preparation of a Notice of Recall, and in some circumstances, a press release. Your firm should review these sections prior to conducting a recall so that you will be familiar with the document requirements and their purpose. It would be beneficial for your firm to maintain "templates" or to prepare sample documents that can be used as examples during a recall. This will speed up the process and ensure that all of the necessary information is included.

As illustrated on the following page, you will recall from Tab 2, page 7, "Recall Procedures", that the recommended steps of conducting a recall are as follows:

Decision to Recall the Product(s)

PROBLEM IDENTIFICATION / DECISION TO RECALL PRODUCT(S)

Problems resulting in a recall may be identified by the manufacturer, importer, consumers or the CFIA. Once a product has been identified as being unsafe or violative by a manufacturer or importer, and you have purchased and sold the affected product, it is your firm's responsibility to take prompt and appropriate action to protect the health of consumers.

STEP 1: ASSEMBLE YOUR RECALL MANAGEMENT TEAM (refer to Tab 2, page 1)

At the very beginning of the recall your firm must:

• Make sure all members of the recall management team are informed of the decision to conduct a recall
• Ensure that each member knows their responsibilities in the recall

STEP 2: NOTIFY THE CFIA (refer to Tab 2, page 4)

Notify the CFIA immediately when you suspect that your firm has purchased and sold a product that may pose a serious risk to consumers. Provide the CFIA with the following information:

• 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 the product was distributed (specific dates)
• label(s) of the product(s) which may be recalled
• the total quantity of product distributed
• the name of your firm's contact with the CFIA
• the name and telephone number(s) for your firm's after-hours contact

This information is pertinent for the CFIA to develop an accurate and complete risk management strategy.

STEP 3: IDENTIFY ALL PRODUCTS TO BE RECALLED

It is your firm's responsibility to ensure that all products which need to be recalled are identified.

STEP 4: DETAIN AND SEGREGATE PRODUCTS TO BE RECALLED WHICH ARE IN YOUR FIRM'S CONTROL

It is your firm's responsibility to ensure that all products to be recalled that are in your firm's control are not sold to consumers. Your firm must:

• determine the locations of the recalled product(s) e.g. on-site at the store, off-site storage
• determine the amounts at each location
• identify and segregate products to prevent offering for sale to the consumer

STEP 5: PREPARE THE PRESS RELEASE (if required)

This step may not apply to your firm. Consult with your CFIA contact to see if you are required to issue a press release.

The purpose of a press release is to alert the public that a product presents a serious hazard to health. Not all recalls require a press release; the CFIA will advise you when a press release is necessary. Where the CFIA is not in agreement with a press release prepared by your firm, the CFIA may issue a separate press release. An example template is provided in Appendix A. In addition, examples of press releases are available on the CFIA website at: www.inspection.gc.ca.

During this step, your firm must:

• decide who will prepare the press release, your firm or the CFIA
• if the firm decides to prepare the press release, include all relevant information (see template, Appendix A)
• complete the press release within two hours after being notified of the recall
• submit a draft of the proposed Press Release to the CFIA for approval
• arrange for translation of the press release

STEP 6: CONTROL OF THE RECALLED PRODUCT(S) (refer to Tab 2, page 6)

If you have returned the recalled product(s) to your supplier, this step does not apply to you.

Your firm is responsible to ensure that recalled products do not re-enter the market.

• separate and clearly identify recalled products(s)
• reconcile quantities and monitor returned product(s)
• record the recalled product(s) in your Recalled Product Records document

STEP 7: FOLLOW INSTRUCTIONS FROM SUPPLIER ON ACTION TAKEN FOR RECALLED PRODUCT

Follow your supplier's instructions for the action to be taken on all recalled product.

STEP 8: FIX THE CAUSE OF THE RECALL

This step only applies if the cause of the problem originated at your store.

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

COMMON PROBLEMS WITH RECALLS, POTENTIAL IMPACTS AND RECOMMENDED SOLUTIONS

Listed below are some common problems, potential impacts and recommended solutions associated with some of the steps in the Recall Procedures.

1. PRESS RELEASE AND NOTICE OF RECALL

Problems:

• the hazard is not clearly described
• the urgency of the recall is not clearly stated
• the key message is obscured by other information, e.g., advertising
• instructions to consumers are not clear

Potential Impacts:

• consumers may not understand the seriousness of the hazard
• hazardous product may not be removed from sale in a timely manner
• consumers may use the recalled product before they are aware of the hazard
• the CFIA or the recalling firm may have to issue a second press release

Recommended Solutions:

• state the hazard clearly e.g., Undeclared (Allergen) in (Product name)
• put the word URGENT in the title of the notice
• be brief and to the point, do not include promotional information
• tell consumers what to do with the product e.g., destroy, return to the store for a refund

2. INFORMING THE CFIA OF A RECALL

Problems

• CFIA is not notified of the recall
• CFIA is notified days or weeks after the problem is identified by the firm

Potential Impacts:

• hazardous product may not be removed from sale in a timely manner
• consumers who purchased the product may use it before they are aware of the hazard

Recommended Solution:

• notify the CFIA immediately if you suspect a product that your firm has sold may pose a risk to the health of consumers

3. IDENTIFICATION OF PRODUCT(S) TO BE RECALLED

Problems:

• all of the sizes, lot codes, brands of affected product are not identified
• other products affected by the recall are not identified

Potential Impacts:

• hazardous product may not be removed from sale in a timely manner
• consumers may use the recalled product before they are aware of the hazard
• the CFIA or the recalling firm may have to issue a second press release
• the firm may have to conduct a second recall

Recommended Solution:

• check with your supplier to ensure that all affected product(s) has been identified

4. NOTIFICATION OF CUSTOMERS

Problem:

• the store decides to remove the product from the retail level without informing customers of the recall
• customers are not notified until days after the recall was classified
• customers are not notified

Potential Impacts:

• consumers may not be aware of the hazard
• consumers may not understand the seriousness of the hazard
• consumers may use the recalled product before they are aware of the hazard
• the CFIA or the recalling firm may have to issue a second press release

Recommended Solution:

• inform all customers of the recall immediately

5. CONTROL OF THE RECALLED PRODUCT

Problems:

• recalled product is accidentally sold to consumers

Potential Impacts:

• consumers may purchase and use the recalled product

Recommended Solutions:

• segregate and clearly mark recalled product(s)
• take precautions to ensure that the product is not accidentally released

APPENDIX A: PRESS RELEASE - INDUSTRY TEMPLATE, ALLERGENS

FOR IMMEDIATE RELEASE

ALLERGY ALERT - UNDECLARED (Name of Allergen) IN (Name of Product)

(CITY), (DATE) -- (COMPANY NAME), (LOCATION) is warning consumers not to consume (BRAND NAME AND PRODUCT NAME) because it may contain (NAME THE ALLERGEN) which is not declared on the label.

The product being recalled is:
(DESCRIBE THE PRODUCT INCLUDING BRAND NAME, PRODUCT NAME, PACKAGING, SIZE(S). LOT #, UPC CODE)

The product is distributed in (NAME THE PROVINCES) or across Canada.

(NAME THE PRODUCT) may cause a serious or life-threatening reaction in persons with allergies to (NAME THE ALLERGEN).

Consumers should (TELL CONSUMERS WHAT TO DO WITH THE RECALLED PRODUCT e.g., return to point of sale for a refund).

There have been (NUMBER) of reported illnesses associated with this product.

Consumers can contact (COMPANY NAME) by calling (PHONE NUMBER).

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For more information, media please contact:

(COMPANY CONTACT NAME)
(COMPANY NAME)
(CITY, PROVINCE/STATE, COUNTRY)
(DAYTIME PHONE)
(AFTER-HOURS PHONE)

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4.0 GENERAL REFERENCE INFORMATION ON RECALLS

Definitions

"Mandatory recall" means a recall as per Section 19 of the Canadian Food Inspection Agency Act.

19.(1) Where the Minister believes on reasonable grounds that a product regulated under an Act or provisions that the Agency enforces or administers by virtue of Section 11 poses a risk to public, animal or plant health, the Minister may, by notice served on any person selling, marketing or distributing the product, order that the product be recalled or sent to a place designated by the Minister."

"Product Withdrawal" means a firm's removal from further sale or use of a marketed product that does not violate legislation administered or enforced by the CFIA. It is not considered to be a recall.

"Public Warning" is a news release that pertains to a specific food recall. The title of this form of communication is "WARNING/MISE EN GARDE". The public warning is issued for those recalls requiring the recall of a product to the consumer level.

"Recall" (verb tense) means for a firm to remove from further sale or use, or to correct, a marketed product that contravenes legislation administered and/or enforced by CFIA.

"Recall" (noun tense) denotes the process of recalling the affected product and encompasses all tiers of the affected product distribution system.

"Recall Classification" means the numerical designation, i.e. Class I, Class II or Class III, assigned by FRER to a particular product recall to indicate the relative degree of health risk presented by the product being recalled.

"Recall Depth" means the level to which a recall is conducted (consumer, retail, distribution).

"Recalling firm" denotes a responsible firm which is accountable for the implementation of a recall.

"Stock Recovery" means a firm's removal or correction of a violative product that has not been marketed or that has not left the direct control of the firm. It is not considered to be a recall.

"Violative Product" is product that violates legislation administered or enforced by the Canadian Food Inspection Agency.

"Voluntary Recall" means a recall that is initiated and carried out by the recalling firm without ministerial order.

Recall Classifications

"Class I" is a situation in which there is a reasonable probability that the use of, or exposure to, a violative product will cause serious adverse health consequences or death.

"Class II" is a situation in which the use of, or exposure to, a violative product may cause temporary adverse health consequences or where the probability of serious adverse health consequences is remote.

"Class III" is a situation in which the use of, or exposure to, a violative product is not likely to cause any adverse health consequences.