Product Withdrawal Procedure Review

Hi,

When you review and rewrite a Withdrawal procedure, do you need to get it audited by Certifying Authority immediately or can you wait till the next cycle of audits.

Thanks,

It is not likely to be necessary.

Most procedures are reviewed and modified over time, and you would not need to get them re-audited. The BRC (and probably most others) require that you tell the certification body of any significant operational and senior management changes between audits so that they can assess whether the change may need to be be re-audited.

Presumably from your post, your existing procedure had been audited and was deemed satisfactory. The principles of your procedure are unlikely to have changed significantly, but the practices obviously may have.

There is a BRC requirement that if you have a real recall, you are required to let the certification body know.

I would say you do not need to notify your certification body of a change to your recall procedure. However, depending on the certification standard you are operating under you will need to ensure you are complying with the standard in regard to changing procedures (if this makes sense?). Your auditors may well seek evidence that your management system has accounted for the change. Let me explain...

Product Recall / Crises Management is a key FSM procedure and process. When you make a substantial change to a procedure you need to ensure the objective of producing safe and legal food has not been adversely impacted. So I would suggest the following:

1. Document the reasons for the change and the specific changes made to the recall procedure.
2. Retain a copy of the old procedure.
3. Conduct a mock recall to test the new recall procedure and confirm its effectiveness.
4. Document the mock recall including overall effectiveness, corrective actions and supporting records etc.
5. Train up all members of the recall / crises management team in the new procedure and update your training records.

Remember - your certification auditors are not there to check every change to your internal procedures. They will however check that you are managing, verifying and validating your food safety management system including key management requirements such as product recall. I hope this is of some help.

George Howlett.

I would say you do not need to notify your certification body of a change to your recall procedure. However, depending on the certification standard you are operating under you will need to ensure you are complying with the standard in regard to changing procedures (if this makes sense?). Your auditors may well seek evidence that your management system has accounted for the change. Let me explain...

Product Recall / Crises Management is a key FSM procedure and process. When you make a substantial change to a procedure you need to ensure the objective of producing safe and legal food has not been adversely impacted. So I would suggest the following:

1. Document the reasons for the change and the specific changes made to the recall procedure.
2. Retain a copy of the old procedure.
3. Conduct a mock recall to test the new recall procedure and confirm its effectiveness.
4. Document the mock recall including overall effectiveness, corrective actions and supporting records etc.
5. Train up all members of the recall / crises management team in the new procedure and update your training records.

Remember - your certification auditors are not there to check every change to your internal procedures. They will however check that you are managing, verifying and validating your food safety management system including key management requirements such as product recall. I hope this is of some help.

George Howlett.

Exellent explanation and detail steps. I would add a small issue:

0. Check that the new recall procedure does not contradict with the regulatory requirments in your country (Report to Health authorities, inform Media etc.)

saguym

Many Thanks for the replies.

I know the info I gave was very limited and your replies have provided the sounding board we needed.

Cheers

Hi SriramB,

Are your using the latest edition of the FSANZ Food Industry Recall Protocol ed Sep 2008?

http://www.foodstand...ocol6thedition/

Hi SriramB,

Are your using the latest edition of the FSANZ Food Industry Recall Protocol ed Sep 2008?

http://www.foodstand...ocol6thedition/

Hi JAKMQA,

The procedure is recently been reviewed and amended to comply with the above document. The suggestion is, we get that audited (asap), and my query was to find out if we were obligated to do so or we wait for normal audit cycle.

Regards

Awesome, SriramB.

Then you're good to go . Have your procedure certified at your next audit.

Cheers.

Hi JAKMQA,

The procedure is recently been reviewed and amended to comply with the above document. The suggestion is, we get that audited (asap), and my query was to find out if we were obligated to do so or we wait for normal audit cycle.

Regards

Please ensure that you have the recall team listed and this should also include the following additions to what has already been mentioned by other members :

Public Realtions Officer to deal with media in the event of a recall.
name and contact number of Solicitor
Name and contact number of Insurance company