Hi,
We produce food contact plastic packaging products, this is up to the Canadian Food Inspection Agency standards. I don't know if it can be useful to you. Maybe check your government's food agency website and you can find information.
Here is our SOP:
Standard Operating Procedure-Product Recall Plan
1. Purpose
Describe the Product Recall Plan that is in place in the operation. The recall plan must be evaluated, and if required adjusted to address any deviations found during mock recall exercises.
2. Scope
It is important that the recall plan be properly implemented and understood by all staff. Since they each have their part to play in insuring product traceability, it is imperative that employees are aware of the importance of the systems put in place to ensure product and consumer safety.
3. Prerequisites
Refer to the Packaging Material Manufacturer & Converter, Food Safety Prerequisite Program Workbook; Section F for more information on the recall and traceability policies.
4. Responsibilities
Even though the recall management team is responsible for most of the steps described in this procedure, it is crucial that all staff is aware of this procedure. This way they can better understand the importance of properly implementing the traceability system.
The following responsibilities will have to be distributed amongst the recall management team: decision making, quality assurance, technical advice, media communications, complaint investigation, contacting customer accounts, CFIA liaison, and legal counsel.
5. Procedure
Follow the complaint handling system procedure to evaluate the complaint and determine if a recall needs to be done.
Complaints are classified in categories to facilitate investigation, in this operation there are three types of complaints:
- product quality complaint
- product packaging complaint
- medical complaint (if someone got sick from using the product).
Every complaint should be deemed important, since it signals that there might be a problem somewhere along the operation procedures, and that corrective actions could be required.
5.1 Procedures to be followed when a serious customer complaint, which leads to a recall, is received:
- Setup a meeting with the recall first-responder team or, if required, the corresponding recall backup team member. Each team member will have specific roles to play in the product recall plan. Refer to table 1 in section 5.2, page 3 for more details about the selected team members, and their respective roles. Refer to figure 1 in section 5.2, page 3 for the recall procedure flowchart.
- Gather enough information from the customer to fill in the following details in the customer complaint record form: contact information of complainant, details of the problem, product details (product no., lot no., etc.), name of company and address where the product was sold, how the product was handled after purchase, and, if required, illness details.
It is important to collect this information, since it will be necessary to provide the CFIA with these details, should a recall be deemed necessary.
- With the information provided by complainant(s), retrace the products using the lot number(s) provided. Gather information about the product lot(s), more specifically: how many items were produced, distributed, and are still in inventory.
- Each lot number is linked to customer account/name, type of account (retail, manufacturer, etc.), customer contact information, and quantity shipped out to each customer. Setup a recalled product record form FR-105 containing the following information: description of product, amount included in recall, date of recall, and after the recall is complete, investigate deviations, and take corrective actions to prevent this problem from reoccurring.
Detain, and segregate the recall products, and if applicable, the raw materials used to produce this lot that are still within the operation.
- If necessary, prepare a press release. A template can be found in sections 5.3 located on page 5 of this document.
- Using the information collected in the previous steps, prepare a notice of recall distribution list.
- Prepare the notice of recall, using the template which can be found in section 5.4, on page 6 of this document. Depending on the class of recall, it might be necessary to have the notice of recall approved by the CFIA prior to its distribution.
Choose the most efficient method of transmission for the recall notice, follow-up with the affected customers to confirm that the notice has been received and take care to contact customers that have not responded back.
It is imperative that a notice is received from every affected customer to confirm that distribution of the recalled product has been halted.
- Assess recall effectiveness by gathering the following information: quantity of accounts notified, quantity of accounts who confirmed reception of the recall notice, method of confirmation of recall notice (fax, email, etc.), and prepare a statement of corrective action if recall was effective OR a statement of corrective action if recall was ineffective. Fill in FR-108 to assess recall efficiency.
- Control the recalled product by setting up a procedure for segregating, and reconciling products, and record all information in the recall record form.
- Establish the proper method to dispose of the recalled products after getting approval from the CFIA. Depending on the situation, the CFIA might require to be present during the disposal of the recalled products. Record each action taken with the recalled product in the recalled product record form FR-105.
- Fix the cause of the recall by putting the proper controls in place to ensure the problem does not reoccur. Take corrective actions anywhere a deviation is found in the operation schematics. It is imperative that the problem be corrected to prevent this type of event from reoccurring.
5.2 Corrective actions:
-Once the recall has been completed, a thorough analysis of the food safety program is to be done. This analysis will serve to determine the program’s problematic areas, which shall be corrected in the briefest delay.
Corrective actions will be put in place once the cause of the recall has been determined.
A product recall is a costly, time consuming process and can easily lead to loss of clients. This is the worse case scenario for most food companies, since it can lead to lawsuits and other legal problems. For these reasons, it is imperative that maximum efforts are put into the product recall procedure.
All documents and records are to be kept on file for a minimum of one year.
