Product Recall Guide Part 2

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Welcome to Part 2 of our two-part Product Recall Guide. We hope that you have been enoying the read so far. In Part 1 of our Product Recall Guide we covered the first three steps in the Product Recall Process. In Part 2, we will consider next steps, Steps 4 to Steps 8.

4. Consumer/Customer Communication

Should the product have already been sold to consumers, notification of the incident and affected product should be communicated to the consumers via media. It is important that the company has pre-determined who will be liaising with the media, and that this responsibility has been defined and documented. The affected customers must initially be contacted by telephone, as this is the fastest way to alert them. This call is then followed up by a formal recall/withdrawal notification. This recall notice should at least contain the following information:

– Product description – Product details – Batch number – Best before date / sell by date – Description of the hazard – Affected sales outlets – Recommendations to address the problem The sales outlets are requested to remove and isolate the affected product so that the product may be uplifted and returned to the manufacturing facility / approved disposal point

5. Recall Products Uplifted

Should the product need to be returned to the manufacturing facility or transported to the point of final disposal/destruction, your company may need additional resources, such as vehicles to collect the product. This logistic task may be contracted in, should the company not have sufficient available vehicles. A list of approved reputable transport companies would need to be included in your product recall plan. The quick and efficient retrieval of the affected product is of utmost importance. The product could either: – Be returned to the facility for additional testing – Disposed of by an approved method Records of all investigations/dispositions must be kept

6. Correct disposal of Recalled Product

The BRC Product Recall Guide suggests that the method of disposal of returned stock should be considered to ensure that it does not compromise consumer safety, damage company reputation or lead to legal issues with respect to environmental damage or risk to animal health. Factors such as the type and quantity of product, risk of reintroduction into the supply chain and the hazardous nature of the product will all contribute to the decision of disposal method. We would suggest asking advice from your local authority / health inspector or from reputable waste contractors before making your final decision.

Important that you document what decisions were made, and what method of disposal was chosen and keep all records to confirm the actual disposal by the certified waste contractor.

7. Correct the cause of the Product Recall

Using your corrective action system, be sure to conduct a thorough investigation as to the cause of the recall and so that you can identify the corrective actions you will need to take prevent any recurrences. Remember to maintain detailed records of all steps taken.

8. Recall Review

Once the recall is complete, it should be reviewed to determined what worked or did not work effectively in the recall/withdrawal and where improvements can be made to make the recall process more efficient next time.

This review is co-ordinated by the product recall team leader and should involve all key personnel who were active in the recall.

Items to include in the review:

Analyse the cause of the issue, identifying immediate and long-term actions to rectify the problems
The robustness of the recall policy and procedures
Effectiveness of the communication strategy
Where designated and accepted roles and responsibilities of the team appropriate
Review the recall documentation
Critical appraisal of key decisions made during the recall/withdrawal
Results of investigations and analysis of returned product
Discussions of possible improvements of the system.

The review must be documented and a report must be kept on file.

The National Consumer Commission requires that a final report be submitted to them. This report must include:

Confirmation on the quantity of affected product supplied
Quantity of product recovered from consumers and supply chain
Evidence to demonstrate that all entities from within the domestic supply chain were notified of the recall
Information about the communication strategy, including copies of data about its effectiveness
Action taken by facility to identify and correct the cause of the hazard, including outcome of root cause analysis, whether defect was manufacturing design or some other defect, and steps taken to remedy problem
Information about any known injuries or incidences related to product
Final number of complaints or inquiries received regarding recall and/or product
Information about manner recalled product was destroyed or rectified, including evidence of destruction or rectification.

Remember, an effective product recall system is required to prevent any harm to consumers and prevent damages to your brand and your market.
Testing your recall procedure once a year by conducting a mock recall is essential to ensure that your team is prepared to handle a food safety incident.

Take a look at the Recall Process Checklist that is provided in the BRC Global Standard Best Practice Guideline Product Recall Issue 2. This is a handy reference to help you check that you have covered the most essentail steps during a Product Recall incident.

Sources of information

National Consumer Commission, Consumer Product Safety Recall Guidelines, 2012
Regulation 638, Regulations Governing General Hygiene Requirements For Food Premises, The Transport Of Food And Related Matters, June 2018
British Retail Consortium, Product Recall Guidelines, Issue 2
Food Standards Agency, Food Traceability, Withdrawals And Recalls Within The UK Food Industry, June 2019
Food safety Authority of Ireland, Product Recall and Traceability Guidance Note, Rev 3

HOW CAN ENTECOM HELP YOU?

Interested in having your team trained on how to handle a Product Recall? Entecom offers a half day Product Recall workshop for your management team We can also assist you with your Mock Recall. Contact us at info@entecom.co.za or call us on (041) 3661970 /80 We look forward to hearing from you.