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ladytygrr

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Posted 27 July 2015 - 06:17 PM

Hi everyone,

 

Can anyone confirm for me (and hopefully point me in the direction of supporting documentation) whether, in the event of a recall or product withdrawal, we need to contact individual consumers that we ship to directly? I am talking about legal (FDA) and/or standard (SQF L2 v7.2) requirements for an RTE snack food producer. 

 

I see that SQF defines a customer as "a buyer or person that purchases goods or services from the certified supplier" which makes me think we have a responsibility with respect to the standard to contact the individual consumer directly but am looking for confirmation from all you experts out there. 

 

Thank you in advance!

 

~Emily~


Edited by Charles.C, 27 July 2015 - 06:29 PM.
I assumed this was not a mock recall

Once in a while you get shown the light, in the darkest of places if you look at it right. -Grateful Dead

 


brianweber

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Posted 27 July 2015 - 06:33 PM

SQF Code, Edition 7.1 – Module 2: SQF System Elements 2.6.2 seems to cover what you are looking for if i am reading this correctly.


Brian


ladytygrr

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Posted 27 July 2015 - 07:09 PM

SQF Code, Edition 7.1 – Module 2: SQF System Elements 2.6.2 seems to cover what you are looking for if i am reading this correctly.

That's the section I was reading, Brian, but in 7.2. I have heard people on my end say that we're not responsible to the direct ship consumer and that seems out of this world to me. :doh:  They are one step forward since we're shipping directly to them. And if that's the case, we have a LOT more documenting to do.  :eek_yello:


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brianweber

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Posted 27 July 2015 - 07:28 PM

I do not see how they can argue the point that they shouldn't be notified. It clearly states "The supplier must have a process in place that enables them to trace product to their customer (one up) and back to the material supplier (one back)."

 

The company is the supplier and the individual consumers that you sell to directly are your buyers. Unless i am missing something completely this seems pretty cut and dry.
 


Brian


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ladytygrr

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Posted 27 July 2015 - 07:44 PM

I do not see how they can argue the point that they shouldn't be notified. It clearly states "The supplier must have a process in place that enables them to trace product to their customer (one up) and back to the material supplier (one back)."

 

The company is the supplier and the individual consumers that you sell to directly are your buyers. Unless i am missing something completely this seems pretty cut and dry.
 

Yay - I'm not crazy (at least not about this  :happydance: )! I will take this and run with it. I guess if they keep pushing back, I guess I'll just have to wait until our pre-audit evaluation or our audit shows that we need to do this. 

 

Thank a bunch!


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brianweber

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Posted 27 July 2015 - 07:50 PM

I can not vouch for your sanity.... :silly: But I would say you are 100% correct on this topic! :welcome:


Brian


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Tony-C

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Posted 28 July 2015 - 03:34 AM

Hi Emily,

 

2.6.2 refers to Trace, In the event of a recall you should also consider how you are going to advise the general public of your recall:

2.6.3 Implementation Guidance
What does it mean?
A product recall applies when a product is found to be unsafe or otherwise in breach of regulatory requirements and is withdrawn from public sale and the consumer market is advised not to use or consume that product. Recalls may be mandatory (i.e., initiated by a regulator), retailer driven, or voluntary (i.e., initiated by the supplier).

 

Regards,

 

Tony
 



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ladytygrr

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Posted 28 July 2015 - 02:05 PM

Hi Emily,

 

2.6.2 refers to Trace, In the event of a recall you should also consider how you are going to advise the general public of your recall:

2.6.3 Implementation Guidance
What does it mean?
A product recall applies when a product is found to be unsafe or otherwise in breach of regulatory requirements and is withdrawn from public sale and the consumer market is advised not to use or consume that product. Recalls may be mandatory (i.e., initiated by a regulator), retailer driven, or voluntary (i.e., initiated by the supplier).

 

Regards,

 

Tony
 

Tony, 

 

Thank you for the additional input and for reminding me about the SQF guidance document. I keep forgetting about it and it's so valuable. 

 

After reading what you added, I started thinking more about it and tried a couple of different internet searches about the FDA's requirement for recalls. I found their Recall Guidance Document and found this:

 

"IMPORTANT: All customers in the distribution chain should be NOTIFIED of the recall, preferably in writing."

 

I believe that is as certain as I can get. So, despite the fact that SQF doesn't require one up traceability to consumers we sell to directly, the FDA does so that means we have to track all of those people. 

 

Many thanks to Tony-C and brianweber for your help.


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Tony-C

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Posted 28 July 2015 - 06:32 PM

Tony, 

 

Thank you for the additional input and for reminding me about the SQF guidance document. I keep forgetting about it and it's so valuable. 

 

After reading what you added, I started thinking more about it and tried a couple of different internet searches about the FDA's requirement for recalls. I found their Recall Guidance Document and found this:

 

"IMPORTANT: All customers in the distribution chain should be NOTIFIED of the recall, preferably in writing."

 

I believe that is as certain as I can get. So, despite the fact that SQF doesn't require one up traceability to consumers we sell to directly, the FDA does so that means we have to track all of those people. 

 

Many thanks to Tony-C and brianweber for your help.

 

No problem Emily, in your initial post you referred to consumers, I would always contact direct customers in the event of a recall, they would be more than annoyed if you didn't.

 

Regards,

 

Tony






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