Food Safety Practices Guidance for Fresh Non-Filled Alimentary Paste Manufacturers
Chapter 8: Complaint Handling and Recalls
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8.1 Complaint Handling
8.1.1 Product Complaints
The establishment has an effective system for handling and investigating complaints.
Product complaints are an important indicator of possible deficiencies in manufacturing controls and/or deficiencies in the distribution handling system. When the complaint handling system itself is deficient, it could result in failure to identify and eliminate risks.
- The manufacturer has a system to handle and investigate product complaints which identifies the person or persons responsible for receiving, evaluating, categorizing and/or investigating complaints.
- Complaints are accurately categorized according to safety, composition and other regulatory concerns.
- Potentially serious complaints are forwarded immediately to appropriate personnel for action.
- Safety and contamination complaints are investigated by appropriately trained technical personnel.
- Examination of the complainant's specimen, the retail product or other product of the same code is conducted on complaints related to food safety.
- Complaints pertaining to composition, fraud and other regulatory concerns are investigated in an effective manner.
- The depth of the investigation is appropriate to the risk and similar complaint trends.
- Appropriate corrective action is taken for deviations identified during the investigation.
See Section 7.6.1 for expected Complaint Records.
8.2.1 Recall Procedure
The fresh alimentary paste manufacturer establishes a written procedure to permit the complete, rapid recall of any lots of fresh alimentary paste from the market.
- A written procedure is in place to enable the recall of any lot of product and provide detailed information to assist in the investigation of any identified produce contamination.
Note: In some instances, the establishment may be required to recall a product because of the use of a raw ingredient or packaging material which has been determined to be unsafe. By linking raw ingredient lot codes to the finished product code, the establishment will be able to identify which of the finished products need to be recalled.
- The written procedure identifies the person or persons responsible (e.g. recall coordinators) and the roles and responsibilities of those who coordinate and implement a recall.
- The procedure specifies methods to identify, locate and control recalled product, and includes a requirement to investigate other products that may be affected by the hazard and should be included in the recall.
- The procedure requires that the recall be monitored to assess its effectiveness (e.g. an "effectiveness check" is conducted to the appropriate level of distribution specified in the recall notice).
- The Canadian Food Inspection Agency is immediately notified in the region where the manufacturer is located. This notification includes the following:
- the amount of product produced, the amount in inventory and the amount distributed;
- the name, size, code or lot numbers of the food recalled;
- the area in which the product was distributed (e.g. local, national, international); and,
- the reason for the recall.
Note: For additional information on developing a recall plan, please refer to the Food Recalls: Make a Plan and Action It! Manufacturers' Guide on the CFIA website.
See Section 7.6.2 for expected Distribution Records.
8.2.2 Recall Capability
Recall procedures are tested periodically to verify the manufacturer's capability to rapidly identify and remove product from the market.
- The manufacturer demonstrates the capability to provide accurate information on a timely basis, to verify that all affected product can be rapidly identified and removed from the marketplace. For example:
- the manufacturer conducts periodic testing (internal simulations) to verify the capability of the procedure to rapidly identify and control a code lot of potentially affected product, and to reconcile the amount of product produced with the amount in inventory and the amount in distribution; and
- the manufacturer identifies and corrects any deficiencies in the recall procedure.
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