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Ragga

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Posted 12 January 2015 - 01:30 AM

Hi All,

 

Just something I wanted some ideas about. We are mainly a manufacturer/wholesaler for QSR's, So our recall procedure has not included a public notification requirement.

 

We have recently started manufacturing product that we sell in bulk which our customer a chain of food retail stores who then packs into retail packs in store (packaging supplied by us) and sells to end consumers.

 

Would I be correct in saying that we don't need to include public notification requirement in our procedure as the chain of food retail stores management should issue this via their QMS upon notification by us? 

 

Now that I have typed this out, I feel my argument sounds logical. But still interested in hearing the opinion of others.

 

 

 

 



Mark Camilleri

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Posted 12 January 2015 - 10:03 AM

I think that in a product Recall, the company should do everything in its power to stop the consumer from eating the food at Risk. 

Therefore although you inform the retailers, I believe that a public statement should be issued to protect the consumers who have already bought the product off the supermarket.

 

Regards

 

Mark 



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Charles.C

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Posted 12 January 2015 - 10:12 AM

Hi All,

 

Just something I wanted some ideas about. We are mainly a manufacturer/wholesaler for QSR's, So our recall procedure has not included a public notification requirement.

 

We have recently started manufacturing product that we sell in bulk which our customer a chain of food retail stores who then packs into retail packs in store (packaging supplied by us) and sells to end consumers.

 

Would I be correct in saying that we don't need to include public notification requirement in our procedure as the chain of food retail stores management should issue this via their QMS upon notification by us? 

 

Now that I have typed this out, I feel my argument sounds logical. But still interested in hearing the opinion of others.

 

Dear Ragga,

 

Google suggests QSR = quick service restaurant ??

 

Not sure i agree with yr predicted timeline (eg "us>>>") although yr query may well relate to local regulatory requirements so only NZd'drs will have a precise answer. But in general, IMEX, it is usually the most direct source, eg distributor, of any significant problem who receives the first onslaught / responsibilities but often rapidly followed by the source, especially if local. From observation recall announcements are also often made by the authorities/Public Health since they are usually directly responsible for managing  FS incidents ?

 

Whose identity is on the labelling ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


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MWidra

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Posted 12 January 2015 - 04:11 PM

Dear Ragga,

 

Google suggests QSR = quick service restaurant ??

 

Not sure i agree with yr predicted timeline (eg "us>>>") although yr query may well relate to local regulatory requirements so only NZd'drs will have a precise answer. But in general, IMEX, it is usually the most direct source, eg distributor, of any significant problem who receives the first onslaught / responsibilities but often rapidly followed by the source, especially if local. From observation recall announcements are also often made by the authorities/Public Health since they are usually directly responsible for managing  FS incidents ?

 

Whose identity is on the labelling ?

 

Rgds / Charles.C

I think the comments may reflect the differences in how recalls are performed in different companies.  In the US, recall announcements are performed most often by the manufacturer because they are actually recalling the material.  The FDA monitors the process, and is notified ASAP when a company announces a recall, but the burden begins on the manufacturer to do the recalling.  The FDA repeats that the manufacturer has recalled the material, but they are usually not the first notification to the public, they amplify it.  (You really don't want the FDA to be the one doing the recall, because that gets you on to the naughty list.)

 

This is compounded in the US because we have two agencies that are involved in food safety, the FDA and the USDA.  And the CDC monitors the foodborne illnesses.  I would be interested in knowing how this all works in other countries.

 

Charles' comments may indicate that in GB, the government is often involved in initiating recalls.  Is that correct?  How does it work in NZ?

 

A good example of how this can start with the originator of the product is the Listeria on caramel apples here.  The apples were sold in retail establishments, and several brands were affected, but it is the original manufacturer who is recalling the product. 

 

http://www.fda.gov/S...rce=govdelivery

 

Martha


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Ragga

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Posted 12 January 2015 - 08:18 PM

I do realise that a notification to public would have to be made in the case of a retail product recall and the responsibility would be on the food manufacturing company. Our companies name is not on the product, our customers is. So I would imagine that due to that fact, they would be the ones issuing the public notification. (In such a scenario we would be working closely with them)

 

This product is bulk packed by us, sent to customers distribution centre. From there they send the bulk cartons to their retail shops where they pack into retail packs and sell only in their branded stores.

 

In NZ most recalls/withdrawals are voluntarily initiated by the manufacturer (but can also be ordered by regulatory body in case of significant safety risk.)

 

P.S Charles correct on QSR comment 

 

http://www.foodstand...tocol-2014.docx



Charles.C

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Posted 13 January 2015 - 02:24 AM

Dear MWidra,

 

I suspect the reasons/actions which can cause/implement a Food Recall are voluminous from a global POV. In most countries I guess the operational decision is ultimately controlled by internal Food Law ( although strong interactions presumably exist in groups like EC). Export/Import trade is another matter.

 

The issue may also involve  FS/non-FS aspects (eg previous post). There is often some responsibility separation regarding (perceived) Safety/Non-safety issues.

For many countries, FS is officially/legally directly under Public Health control. I think this is case in UK via the FSA. Options for FS recall are then dictated by FSA afaik. Non-FS I’m not sure. NZ no idea as to the top body.

 

The linked activities/interpretations of  “withdrawal / recall” seem to also be quite common globally, eg UK again. And Australia from memory. USA/NZ I’m unsure again.

 

In USA, the (probably) near-unique usage (from a FS POV) of “Adulteration” is perhaps most famous (notorious) to outsiders, and perhaps for avoiding the “naughty” tag to insiders also (?). This “opportunity” seems to overlap FDA/FSIS. Plus the US State/National interactions are relatively unusual I think (also in Australia maybe). NZ unsure.

 

And then you have imports.

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


MWidra

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Posted 13 January 2015 - 03:59 AM

Hi Charles:

 

I'm sure that the "Adulteration" term is even more puzzling to "foreigners" than it is to Americans.  But both the FDA and the USDA were originally interested in protecting the consumer from drugs and agricultural products that were not what they appeared to be or that were not what the label described.  The USDA is still very interested in keeping the amount of additive in an agricultural product small enough that the consumer is really getting ground beef when it says ground beef and not ground corn with a little beef.  They take that just as seriously as the inspection of meat.  The FDA (who began with activities through the Patent Office) started worrying about agricultural products and medicines that had been adulterated or mislabeled.  Food Safety was not a discipline back then.  Now the FDA worries about safety, but the old terms stuck.

 

http://www.fda.gov/A...tWeDo/History/ 

 

The interactions between the Federal and State governments in the U.S. are probably unique in the world.  We play nicely together, and the Feds are the Big Boys, but the states take care of their turf and are Top Dog there.  We squabble in Washington D.C., and smile at each other everywhere else.  Separation of Powers works for us, lol.

 

Just like the EC countries, imports have to abide by U.S. law.  The FDA is spread very thin, so when unscrupulous people in other countries (or here) try to get away with something, it is hard to catch every one.  Just as it works for recalls, the FDA depends on importers and just plain citizens to blow the whistle on problems.  That's why companies voluntarily issue the recalls and there is no stigma attached, they were doing their job.

 

That feeling that everyone is responsible for the common good here is part of the source of that separation of powers, that everyone has to contribute to the safety of the country as a civic duty.  Unfortunately, these days people don't seem to want to "get involved" in pulling their share, and bad guys get away with more.  I'm hoping that the pendulum swings more in the other direction.  We would see less crime, less people hungry, and less terrorist attacks succeed if the people started getting involved again.

 

Sorry for the rambling, but we were talking about how the different countries treated food safety differently, and Charles brought up the "A" term, so it just flowed.

 

Thanks for reading to the end.

 

Martha


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CMHeywood

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Posted 15 January 2015 - 03:15 PM

You may not be required to make a public statement but it would be a good idea to have a formal plan for addressing inquiries from the media, the public, or lawyers.  For example, no one talks to these people except for Mr/Ms XXX, your official statement can be found on your website, copies of official statements can be obtained from XXX.






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