Recall procedure: A guide for food businesses
The Canadian Food Inspection Agency (CFIA) created this guidance to help you prepare a recall procedure to carry out effective recalls. It may also be used to assist you with complying with the requirements of the Safe Food for Canadians Regulations (SFCR) regarding recall procedures (subsection 84(1) and section 85 of the SFCR).
The term "recall" is not specifically defined in the Safe Food for Canadians Act nor in the Safe Food for Canadians Regulations. In general terms, "recall" refers to the removal of a food from further sale or use, or the correction of its label, at any point in the supply chain as a risk mitigation action.
Other guidance developed by provincial governments, industry associations, international organizations or academic bodies may also be used as long as the recall procedure that is developed will achieve the outcome of an effective food recall. Always ensure that the guidance you choose is relevant for your particular business, product and market requirements.
What is included
This guidance provides a step-by-step approach that you may wish to consider for your recall procedure to implement a recall quickly and effectively.
Roles and responsibilities
You are responsible for complying with the law and ensuring that food for which you are responsible for is safe for human consumption. You may demonstrate compliance by ensuring that the food, the establishment in which the food is prepared and any activities conducted in relation to the food (among other areas you may be responsible for) meet relevant legislative requirements including food safety and, where applicable, those pertaining to food recalls.
During a food recall, the CFIA's role is, generally, to:
- ensure that recall activities are sufficient to the risk posed to consumers,
- issue recall warnings when necessary and
- verify that you have effectively removed the food from further sale or use, or corrected its label
1.0 Step-by-step recall procedure
The following twelve steps are best practices that could be incorporated into your recall procedure.
Step 1: Assemble your recall management team
Identify persons in your business who would be involved in implementing a recall and assign duties to each person. This will allow you to action your recall procedure in an effective manner. The number of members in your recall management team will vary according to the size and structure of your business.
In your recall team, you should consider including people who are responsible for:
- complaint and food incident investigations
- quality assurance/technical advice
- decision making
- the recall procedure
- media and consumer communication
- contacting and liaising with the CFIA
- legal advice
Consider having the following details for each member, including after-hours contact details as recalls may be needed at any time:
|Responsibilities||Name and position||Business phone number||After hours phone number||Alternate person name and position|
|The duties assigned to the person||Name of the person and their position title||xxx-xxx-xxxx||xxx-xxx-xxxx||Name of the alternate and their position title|
At the start of a recall, the person who is responsible for conducting recalls within your business should assemble the recall management team, or any other person assigned to help with the implementation of the recall, and ensure that:
- all members are informed of the decision to conduct a recall
- each member knows their responsibilities during the recall
Review and update the membership of your recall team and their details on a regular basis.
Step 2: Notify the CFIA
Immediately notify the CFIA recall coordinator who covers the area where your business is located if the CFIA is not already aware of the incident.
To allow the CFIA to assist you in your investigation, and to take any further action, if needed, to protect the public and mitigate any potential risk of injury to human health, the recall coordinator may ask you to provide the following:
- A detailed description of the nature of the problem
- The food name, brand, size and lot code(s) or other unique identifier affected
- Label(s) of the food in question
- The total quantity of food affected and the quantity distributed (that is, left your business' control)
- Information on the geographical area of distribution of the affected food (for example, locally, intra-provincially, inter-provincially, nationally and/or internationally)
- When the food was distributed (specific dates)
- Details of complaints received and any reported illnesses
- Contact information of your staff member responsible for liaising with the CFIA
- The name, telephone number(s) and email address of your business' after-hours contact
If the food is already being recalled when you notify the CFIA, the recall coordinator may ask for the following:
- The notice of recall
- The distribution list
- The press release, if you are issuing one
Step 3: Identify all food to be recalled
In addition to the food directly affected, determine if:
- any other sizes, brands, or codes or unique identifiers of the same food are affected
- any other food is affected
If this is the case, include this food in your recall.
- Have a traceability system that will allow you to be best prepared for an effective recall. Refer to Part 5 of the SFCR for the regulatory requirements related to traceability.
- Recalls can be triggered by ingredients that were incorporated into your food. To better target affected foods, consider documenting the lot codes or unique identifiers of each ingredient that you incorporate into your food.
- Recalls may also be caused by unsafe packaging material. Ensure you can link packaging materials to the food lot codes you are responsible for. Consider documenting and implementing the following practices:
- Associate packaging materials to their suppliers
- Associate packaging materials to your food lot codes
Step 4: Hold and segregate food included in the recall that is still in your control
Ensure that all the food affected by the recall that is still in your control is not distributed by:
- determining the locations of the affected food (for example, on-site, at the plant, off-site storage)
- determining the quantity of each affected food at each location
- identifying and segregating the affected food
Step 5: Review the CFIA public food recall warning (when applicable)
The CFIA will inform you if a public warning to inform consumers is required when you conduct a voluntary recall. The CFIA prepares the public warning using a standard template and asks you to review it to ensure the accuracy of your food business' name, the description of the recalled food and its distribution. If you wish, the CFIA can add your contact information for consumers and/or the media. Once finalized, the CFIA sends English and French versions of the public warning for dissemination to the media and posts it on the CFIA's and the Government of Canada's Health risk and safety websites.
Step 6: Prepare the distribution list
As the business conducting the recall, create a food and lot code specific distribution list, that identifies:
- each client's name and address (street address, unit number, city/town, province)
- the name, telephone number(s) and email address of your contact at each client
- the type of client (for example, distributor, retailer, clients who serve vulnerable population, such as hospitals, care homes, daycares)
- the amount of recalled food per lot code, when applicable, shipped to each receiving client
The CFIA will ask to receive the list as soon as possible after the initiation of the recall.
Ensure you have a complete list of clients by adding together the amount of affected food for each client on your distribution list to the quantity of affected food that is still under your control. If this sum is less than the total quantity of the food to be recalled, you may need to review your list of clients and/or verify the inventory of affected food in your control.
Step 7: Prepare and send the notice of recall
As the business conducting the recall, immediately notify all of your clients who received or may have received the recalled food. Consider:
- writing a notice of recall and include all relevant information (refer to Annex A for a notice of recall template)
- sending the draft notice to your CFIA contact for review. If a notice of recall contains inaccurate information and/or is incomplete, the CFIA may ask you to revise it
- sending your notice of recall to each client on your distribution list
- asking your clients to confirm receipt of the notice and indicate the actions they have taken
If it is not possible for you to notify all clients simultaneously, prioritize the notification and contact distributors and clients who serve vulnerable populations (for example, hospitals, care homes, and daycares) first.
You may consider using the notice of recall to obtain additional information from your clients, such as:
- how much of the recalled food remains in their possession
- how much of the recalled food has been further distributed
Step 8: Verify and document the effectiveness of the recall
To ensure an effective recall, verify that the clients to whom you shipped the recalled food:
- were notified of the recall
- took appropriate action, such as returning the affected food to your warehouse, destroying the food, informing their clients if the food was further distributed, etc.
Document the results of your verification as follows:
- The date when the clients were contacted
- The method of contact (for example, by telephone or e-mail)
- The name of the person contacted at each client
- The action taken by each client (for example, returning the food to your warehouse)
- The quantity, and if readily available the lot code, of each food recalled on each client's site at the time of the recall
- The result of your verification (that is, whether the recall was effective or not)
- How you determined that your recall was effective
- The corrective action taken when it was determined that the recall was not effective
Contact the clients who have not confirmed receipt of the notice of recall.
The CFIA may follow-up with some of your clients to verify the effectiveness of the recall. If the CFIA determines that your recall was ineffective, the CFIA may ask you to repeat the recall.
Step 9: Control the recalled food
To prevent the recalled food from re-entering the marketplace:
- segregate and clearly identify recalled food
- reconcile quantities and monitor returned food affected by the recall
Step 10: Decide what to do with the recalled food
Decide what disposition action you will take on the recalled food (for example, correction, re-export, destruction) and inform the CFIA of your decision. The CFIA will review your method of disposition and may request to witness the disposition prior to its implementation.
- verify that your disposition action was effective
- document the disposition action taken for each recalled food in your food recall documentation
Step 11: Choose a corrective and preventive measure
Identify the cause of the incident that led to the unsafe food. Ensure appropriate corrective actions are in place and that preventive measures are implemented to prevent similar recalls in the future.
Document the measures taken in your food recall documentation.
Be prepared to demonstrate the effectiveness of your corrective and preventive measures to the CFIA.
Step 12: Conduct a post recall review
After conducting a recall, meet with your recall management team or with those who helped with the implementation of the recall and discuss how the recall went. Document the following in your food recall documentation:
- The effectiveness of the recall (established in step 8)
- Any problems you identified during the recall implementation
- How the recall procedure was amended to address any problems identified
- Other improvements in any other areas to prevent reoccurrence of the identified problems.
2.0 Tell me more. Further reading
If you are subject to the Safe Food for Canadians Act and its Regulations, the following documents prepared by the CFIA contain information that help explain food safety controls, demonstrate how to develop them and provide examples:
- A guide for preparing a preventive control plan for domestic food businesses
- Corrective actions
- Conducting a hazard analysis
- Determining critical control points
- Critical limits
- Preventive control plan templates for domestic food businesses
- Monitoring procedures
- Verification procedures
Notice of recall template
Urgent – Recall of (enter food name)
(enter name and address of your business)
Dear Customer or Attention (enter name of customer contact),
(enter your business name) is recalling the food listed below because (state the reason for the recall, for example, presence of an allergen not declared on the label, bacteria [name], foreign pieces of material, etc.).
Please discontinue the distribution, sale or use of the food immediately. Remove the food from stock or display, count the quantity still under your control and ensure that the food will no longer be distributed, sold or used. Please do this by [insert one of the following two sentences]
 storing all recalled product in a secure, segregated place and mark as "recalled"
[Include a paragraph providing information, as appropriate, regarding your business' policy on crediting for recalled food, identification of recalled food with the mark "recalled" and arrangement for the pick-up recalled food. Example: We will credit you for the recalled food. Please mark the food "recalled" and our staff will call you to arrange pick up.]
 proceeding with the destruction of all recalled food in such a manner that they cannot be sold or used
[Include a paragraph providing information, as appropriate regarding your business' policy on crediting for recalled food]
If you further distribute this food, please immediately contact all your clients to whom you distributed this food and inform them of this recall and actions they should take on the food.
If any of the recalled food is repackaged, relabelled or reworked by your business, your final product may also pose a health risk. Please contact your local CFIA office immediately should this situation apply.
Please acknowledge receipt by signing and sending this document (via fax or e-mail) to (enter your business' contact name) at (enter your business' fax number or e-mail address).
Date / Time Received:
Name (please print):
Thank you for your cooperation.
(enter your business' contact, their position and your company name)
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