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When to notify CB or SQFI for a Recall

Recall quality food safety rancidity

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#1 LindaALaw

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Posted 06 June 2016 - 06:08 PM

Good Day,

 

I have read through several threads regarding the provision to contact your CB & SQFI in the instance of a recall but could use some clarification.....

 

We have decided to voluntarily recall some product which was triggered by several complaints we had regarding the products odour and taste.  When we had the product tested, the Peroxide Values are high enough to consider the product "Rancid".

 

Would this be considered a "food safety incident" or a quality issue.  Most articles I've read indicate that people will not become ill because of rancidity thus we are informing our customers/distributors that it is a Quality issue.

 

Basically, I'm not sure whether I should contact the CB and/or SQFI regarding this issue.  We have just been recommended for certification to SQF 7.2 Level 2.  We don't even have our final certificate yet, so I don't want to compromise our certification by making any incorrect assumptions.

 

Any suggestions would be appreciated  :uhm:

 

Linda


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#2 GMO

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Posted 06 June 2016 - 08:24 PM

I can't talk for SQF but certainly when it comes to BRC and other standards, the question would be whether it was a recall or a withdrawal.  

 

  • A recall = public notices, telling consumers etc.
  • A withdrawal = retailers removing it from their depots and possibly also their shelves but not contacting consumers

 

In most standards, you only have to inform about a recall.  I did have one in a former place of work and it was absolutely fine.  It didn't impact on the next audit, they didn't come out and reaudit or anything.  I also made sure we'd reviewed our HACCP plan because of the recall too.


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#3 LindaALaw

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Posted 07 June 2016 - 01:12 PM

We don't plan on public notices since we don't consider it a food safety issue.  We have asked Retailers to remove from their shelves and return any of the product back to us.

 

Good suggestion about reviewing our HACCP Plan since obviously there was a gap somewhere in our Receiving processes.

 

Thanks for your feedback.


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#4 pooled

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Posted 07 June 2016 - 01:21 PM

I agree, SQF is notification within 24rs of a recall but this sounds like a withdrawl. Have you performed a risk analysis on the product?


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#5 RMAV

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Posted 07 June 2016 - 01:37 PM

I believe within the letter of the SQF code, you're OK to not report it.  In my recent experience, I found it easy to stay on the safe side and report it anyway.  My CB seemed to appreciate it and the issue received very light scrutiny during my last audit.  My suggestion is whenever you notify CB and SQFI, notify the CB first and seek their advice.


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#6 LindaALaw

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Posted 07 June 2016 - 02:11 PM

Another good suggestion....performing a Risk Assessment. 

 

Since we're brand new to SQF, we are not very well versed in Risk Assessments but I certainly will include this as a "Preventive Action" in my final review.

 

Thanks all, for you help!


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#7 amppyr

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Posted 07 June 2016 - 09:38 PM

Hi,

 

SQF 7.2 clause 2.6.3.1: The responsibility and methods used to withdraw or recall product shall be documented and implemented. The procedure shall:
 
iv. SQFI and the certification body shall be listed as an essential body and notified in instances of a food safety incident of a public nature, or product recall for any reason. 
 
I would interpret this for notification during a recall for any reason. I suppose you could interpret it as a not requiring notification because it is not a food safety incident.
 
CBs and SQFI will contact you but once you provide them with the information concerning the recall and that it is not a threat to public health, it will be fine.
 
 
Thanks.
amppyr

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#8 GMO

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Posted 08 June 2016 - 07:11 AM

I believe within the letter of the SQF code, you're OK to not report it.  In my recent experience, I found it easy to stay on the safe side and report it anyway.  My CB seemed to appreciate it and the issue received very light scrutiny during my last audit.  My suggestion is whenever you notify CB and SQFI, notify the CB first and seek their advice.

 

It's a good point, you're not likely to come off worse by reporting it unnecessarily.  If you let them know you've had a withdrawal and you're not sure if you should inform them of it, they will probably say you don't need to but the box is ticked come audit that you've been open and honest.


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#9 LindaALaw

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Posted 08 June 2016 - 12:51 PM

I agree that we should inform the CB and SQFI regarding the Withdrawal.  We are not trying to hide anything, we're just trying to prevent sub-standard product from flooding the consumer market.

 

The entire exercise has been a good learning experience as well.  Although we followed all the correct steps in our "Withdrawal/Recall Plan", we can certainly improve the process to make it more streamlined in the event of a real emergency.


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