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Product Recall & withdrawal


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#1 sahe

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Posted 25 May 2007 - 11:17 AM

I would kindly appreciate if anyone could give me definition and describe difference between recall and withdrawal.
Also, have you been testing this procedure and how???
Thanks


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#2 MartLgn

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Posted 25 May 2007 - 12:26 PM

Hi Sahe :welcome:

As I understand it a withdrawal is the removal by a supplier of product/material in the supply chain whereas a recall involves product that has been sold or is with the end retailers and available for sale.

For example if a packaging supplier delivered a consignment of containers into a food manufacturers which they subsequently found to be faulty they would withdraw the containers from the customer. If the containers had been used and sent to market then the brand owner/producer would recall the faulty filled containers from the public and retailers.

Many of the Food Safety Mangement standards require a periodical test of the withdrawal system to be carried out.

The first step is to choose a batch of product that is hypothetically defective.

Dependant on the size of your company it can be a very simple procedure such as interogating your order system to find out where the product in question went to. The contact with your customer is the easy part of the exercise once you have located the wherabouts of the product, many companies do not actually involve the customer as it can lead to unfortunate and possibly expensive confusion.


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Why put off until tomorrow that which you can avoid doing altogether ?

#3 okido

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Posted 25 May 2007 - 12:27 PM

Hello Sahe,

You can find the following definition in the NZFSA Recall Quick Reference Guide.

NZFSA Recall Quick Reference Guide

Quote from this quide:
“What is Recall?
Recall is the isolation and removal of food which has been released from a manufacturer’s direct
control, and is under the control of others in the storage, distribution, retail, and consumer chain.
There are two levels of product recall. These are:
Recall: This is a removal of unsafe or unsuitable food from the distribution chain and extends to food
sold to consumers and therefore requires effective communication with consumers.
Withdrawal (also known as Trade Recall): This is the removal of an unsafe or unsuitable foodstuff
from the distribution chain but does not extend to food sold to the consumer.”

Testing recall procedures is standard operation I would say.


Have a nice day, Okido


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#4 Charles.C

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Posted 25 May 2007 - 04:35 PM

Dear Sahe,

The appropriate meaning may depend where you are and what situation you are talking about, not to mention the consequences. Life is so simple. :biggrin:

A later version (2006) of Okido’s reference seems to have changed the idea a bit (I think) – the term “withdrawal” is only applied to a situation where the item is considered a non-health risk, otherwise has to be a “recall”, plus some terminology extensions.
http://www.afgc.org....20Processes.pdf
also has nice but non-simple IMO flow chart - http://www.afgc.org....owchart v11.pdf

There may well be another version after this ?

The situation in EU appears controlled by Regulation (EC) No 178/2002 which has the usual Guidance document http://www.food.gov....afetyguide2.pdf
(Article 19 in particular)
It is very detailed and probably very good but I surrendered to boredom half way through although I did notice this –
“III.3.
Contribution/ Impact
III.3.1.
Article 19 (1)
i)
Obligation to withdraw
Article 19 (1) imposes the specific obligation on food business operators to withdraw from the
market a food that does not meet the food safety requirements and inform the competent
authorities thereof.
Regarding a definition of withdrawal, reference can be made to the definition laid down in
Directive 2001/95/EC on General Product Safety which states that “withdrawal means any
measure aimed at preventing the distribution, display or offer of a product dangerous to the
consumer”.
It has to be underlined that in the context of Article 19:
- The withdrawal from the market may take place at any step along the food chain and not
only at time of delivering to the end consumer;”

Seems FSA are currently deliberating/consulting on this document, ie -
“United Kingdom: Food Standards Agency Issues New Draft Guidance Notes On The General Food Law Regulation (EC) 178/2002, 19 January 2007” ….. I extracted this chunk –

“NOTIFICATION UNDER ARTICLES 19 AND 20
Although there are no material differences between the draft FSA Guidelines and the EC Guidelines, a summary of the notification requirements for food and feed and the differences between them follows. Articles 19 and 20 impose an obligation on food and feed businesses to recall and/or withdraw food and feed if they do not comply with the safety requirements of Articles 14 and 15 respectively.
Food
Article 14 provides that food shall not be placed on the market if it is "unsafe" which it defines as being either injurious to health6 or unfit for human consumption7.
Article 19 paragraph 1 provides that where a food business operator considers or has reason to believe (the applicable test to be an objective one) that a food which it has imported, produced, processed, manufactured or distributed:
is not in compliance with the food safety requirements; and
has left the immediate control of the initial business food operator,
the competent authorities should be notified and immediate procedures should be initiated to withdraw84 the food from the market. Even if there is some uncertainty as to whether or not the food is in breach of the food safety requirements, the obligation under Article 19 still operates.
Where products have reached the consumer, there is an obligation on food businesses to inform consumers effectively and accurately of the reason for the withdrawal of the product (detailing why the product is unsafe) and to initiate a recall9 of products already supplied. This obligation also applies to food business operators responsible only for retail or distribution activities10.
If food which does not meet the food safety requirements has not left the immediate control of the food business operator, removal of the food from the food chain does not constitute a withdrawal meaning that there is no obligation to notify the competent authority. However, obligations may still arise under Article 19(3).
Under Article 19(3), if a food placed on the market is potentially injurious to human health, the competent authorities should be notified immediately11 advising them of action taken to minimise the risk to the final consumer. Note that this obligation only applies to food which is potentially injurious to health, not food which, although unfit for human consumption, is not potentially injurious to health.”
I think some of this agrees with Martin’s suggestion, some bit like NZ, some not sure at all.
Maybe the result is already available somewhere or changed again?

Of course, if one is in the USA…… :helpplease:

Rgds / Charles.C


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