21.12 Product recall and otheremergencyprocedures
A product defectcomingto the manufacturer's attention, whether througha
complaintor otherwise,maylead to the needfor a productwithdrawalfromthe
retail distribution system, or a publicproductrecallalsoinvolving returnof
products by members of the public.In suchsituations,product identification and
traceabilityof products, theiringredients and theirpackagingmaterialsare
cruciallyimportant.
Thereshould be a predetermined written plan, clearlyunderstoodby all
concerned,for the recallof a productor a knownbatchor batchesof product
known or suspectedto be hazardousor otherwise unfit,or the withdrawalor
recall of wholesomebut substandard product whichthe manufacturerwishesto
withdraw or recall. A crisis procedure and management team should be
established.A responsible person,withappropriate named deputies, should be
designatedto initiate and coordinate all withdrawaland recallactivities,to liaise
withretailers,and to be the pointof any contactwiththe regulatoryauthorities
on recallmatters.
The design of manufacturing records systems and distribution records
systems,and the marking of outer cartonsand of individualpacksshould be
suchas to facilitateeffectivetraceability, withdrawalor recallif necessary.A
goodsystemof lot or batch marking will pinpointthe suspect material and help
avoid excessive withdrawal or recall.
Thereshould be written withdrawaland recallprocedures,and they should be
capable of being put into operation at shortnotice,at any time, insideor outside
workinghours. The procedures shouldbe shownto be practicableand operable
within a reasonable timeby carrying out suitabletesting. They should be
reviewed regularly to checkwhether thereis needfor revisionin the lightof
changes in circumstancesor of the responsibleperson.
Product withdrawalsor recallsmay arisein a variety of circumstances,
which,however, fall into three maincategories:
- wherethe regulatory authoritiesbecomeawareof a hazardor suspected
hazard,and informationand cooperationfromthe manufactureror importer
is necessitated; - wherethe manufacturer, importer, distributor, retailer or caterer becomes
awareof a hazardor suspectedhazard; - wherethereis no hazardor suspectedhazard involved, but thereis some
circumstance(e.g.substandard quality,mislabelling)whichhas come to
lightand whichprompts the manufacturer,importer or retailer to decideto
withdrawor recall the affected product.
In case(3), the companywill itselfhaveto organise the withdrawalor recall
operation.In cases(1) and (2), considerationmaybe given to issuinga public
Food HazardWarning.Generallythis wouldbe donein consultationamong the
manufacturer or importer, the distributor or retailer,and any relevant enforce-
ment authority interest. Normally any arrangements for recall would be
342 Handbookof hygiene controlin the foodindustry