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#1 marisakaye

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Posted 06 October 2017 - 02:00 PM

Hello everyone, 

I'm usually mostly a lurker, and this forum has provided me with so much valuable information.  However I do have a question that I cannot seem to find a good answer to.

 

Our company produces both RTE refrigerated and RTC frozen items that are sold in convenience stores.  Most are sold in cases intended for preparation and consumption "on-site".  However, we have added label stickers to a few items and have apparently given the option to our stores to also sell these at retail (this apparently happened before I was with the company). The problem that I see with this is that there is no lot coding printed on the individual items that are offered for potential retail sale; only on the cases containing the individual items is there printed lot information. 

 

I've done hours of searching and from what I can see, there is no specific legislation from either the FDA nor the USDA (we are dual jurisdiction) requiring lot numbers on RTE/RTC frozen items.  However I do realize the potential risk this presents with our company in the event of a recall situation involving individual items sold for retail without a lot number. I deduce this would mean a complete and total recall, possibly involving every item produced on that specific line.

 

Is there specific legislation that I've missed somewhere regarding lot numbers on individual retail items? And are there other risks to our company that have not been realized thus far? 

 

Just wanted to gather some thoughts on the issue so I can present the risk to management in terms of realistic potential consequences. 


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#2 FurFarmandFork

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Posted 06 October 2017 - 05:38 PM

Depending on the details of  your situation, you may be extending your responsibility for recall further than you need to. You are only responsible for recalling "one level down", which would the the cases you sell to the stores (unless you own the stores I suppose..don't know what your business scope is). The stores are then responsible for maintaining tracebility (if any) they need for serving direct to consumers.

 

E.g. if ma's meat mart opens up your case and sells individual chicken breasts, they're responsible for informing customers if they have a recall (all chicken sold between date X and date X is being recalled), if they don't track that information then they would have to recall all chicken sold. So they need to either track when they sold what case lots, or mark them further at the store level. You only have a responsibility to the point where you lose ownership of the chicken.

 

Be careful with USDA labeling though when labeling individual retail units, I've submitted a lot of askFSIS queries regarding point of sale, and typically they don't want you adding any labeling to individual packaing inside unless it contains all required components for point of sale (inc. nutrition etc.).

 

Some definitions for different layers of packaging for amenable products: https://askfsis.cust...Hg5NXclMjElMjE=

 

FDA FSMA Recall requirements:

 

(a) You must establish a written recall plan for the food.

(b) The written recall plan must include procedures that describe the steps to be taken, and assign responsibility for taking those steps, to perform the following actions as appropriate to the facility:

(1) Directly notify the direct consignees of the food being recalled, including how to return or dispose of the affected food;

(2) Notify the public about any hazard presented by the food when appropriate to protect public health;

(3) Conduct effectiveness checks to verify that the recall is carried out; and

(4) Appropriately dispose of recalled food--e.g., through reprocessing, reworking, diverting to a use that does not present a safety concern, or destroying the food.

 

 

FSIS product dating guidance (and additional requirements for frozen foods): https://www.fsis.usd...JTZ9B_9fjN8!/#2

 

Poultry product lot coding requirements: 9 CFR Section 381.126(a)


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#3 marisakaye

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Posted 06 October 2017 - 06:02 PM

 

Be careful with USDA labeling though when labeling individual retail units, I've submitted a lot of askFSIS queries regarding point of sale, and typically they don't want you adding any labeling to individual packaing inside unless it contains all required components for point of sale (inc. nutrition etc.).

 

 

 

 

Luckily the individual retail label stickers contain all of the required information (nutritional, ingredient dec, etc.) according to USDA labeling guidelines.  Just no lot code info.


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#4 FurFarmandFork

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Posted 09 October 2017 - 02:43 PM

 

Luckily the individual retail label stickers contain all of the required information (nutritional, ingredient dec, etc.) according to USDA labeling guidelines.  Just no lot code info.

 

Gotcha, then yeah, if you're not selling those, it may be up to the retailer to then recall all items sold (and I'm sure they'd pass that cost to you via supplier agreement) and/or all items sold between x and x date.


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