BRC/IoP Global Standard - Issue 5 - Recall v Withdrawal
Can anyone help me with clarification on Recall v Withdrawal procedures for the new edition of the standard.
We manufacture secondary packaging (Low risk category) and some of it goes to food producers. I have read the standard and the interpretation guidelines as well as various articles on line and am totally confusing myself.
My initial thoughts are that a :
PRODUCT WITHDRAWAL is initiated by us, e.g we find a manufacturing defect in a batch which may also have occurred in a batch already sent to a customer. We withdraw that batch plus any product we have in stock. Or a customer complains that text is missing and returns the cartons. We withdraw all the batches.
PRODUCT RECALL is when a customer needs to recall it's product and needs us to provide them with batch details for what we have supplied
Can anyone confirm / clarify?
Any help greatly appreciated.
My understanding is that a recall is from the marketplace but a withdrawal is when it is just from your customers.
So YOU would withdraw the product from your customers and your customers would issue a recall to remove the product from the consumer
Recall- Retailers/brand owner initiated
Withdrawal- you or customer complaint returns
Need to have a procedure showing
Recall Withdrawal
Key personnel and responsibilities
Communication plan
Annual test (withdrawal)
Emergency out of hours contact list
Make sure training is carried out.
Hope this helps
My understanding is
Withdrawal can be initiated by anyone but is limited to warehousing/stores. (confined to industry)
Recall can be initiated by anyone and will involve the consumer. (involves the public) Returns of their purchases. Alerts via the media-posters in store ,press adverts, radio announcments
I would say a Recall is when product is taken off shelves and consumers notified to return product - food safety Issue that may harm consumer.
Withdrawal would be when product is taken off shelves only - may be more a quality issue than safety?
PRODUCT WITHDRAWAL is initiated by us, e.g we find a manufacturing defect in a batch which may also have occurred in a batch already sent to a customer. We withdraw that batch plus any product we have in stock. Or a customer complains that text is missing and returns the cartons. We withdraw all the batches.
PRODUCT RECALL is when a customer needs to recall it's product and needs us to provide them with batch details for what we have supplied
I disagree.
PRODUCT WITHDRAWAL can be initiated by you or by your customer but it is a "quiet" process, i.e. if any products are in consumers homes, they would not be told through the press to return or dispose of the product. This would commonly be used for lower risk issues, e.g. quality issues, non food safety issues or it might be for a food safety issue if all parties are confident the product has not reached consumers homes.
PRODUCT RECALL can be initiated by you, your customer or a competent authority e.g. EHO, food standards agency etc. This would be a public process, i.e. notices in newspapers, web alerts etc and would include recall from consumers homes as well as withdrawal from the supply chain.
So the difference is where in the supply chain you are removing the product from, not really who initiates it IMO.
There seems to be a wide variation to the interpretation for these terms!
For our system we have kept it simple. We have defined that withdrawal is for product that is still under our control, i.e. up until its arrival at the customer, while recall applies to materials that have gone beyond our direct control, i.e. post-delivery to the customer.
We have set up a procedure to cover both potential situations, which we audit annually.
We had our BRC audit last week and this interpretation was accepted.
There seems to be a wide variation to the interpretation for these terms!
For our system we have kept it simple. We have defined that withdrawal is for product that is still under our control, i.e. up until its arrival at the customer, while recall applies to materials that have gone beyond our direct control, i.e. post-delivery to the customer.
We have set up a procedure to cover both potential situations, which we audit annually.
We had our BRC audit last week and this interpretation was accepted.
This would contradict with some retailers interpretations of the term; "withdrawal" is certainly understood as being return from customer by Tesco as in EPW = emergency product withdrawal from their supply chain.
Perhaps I should clarify here customer = retailer or B2B customer, consumer = person who is going to eat the product.
Perhaps the definitions from the BRC Global Standard for Packaging and Packaging Materials Issue 5 will help:
Product recall - Any measures aimed at achieving the return of an unfit product from customers and final consumers.
Product withdrawal - Any measures aimed at achieving the return of out-of-specification or unfit products from customers, but not from final consumers.
Kind regards,
Tony
This would contradict with some retailers interpretations of the term; "withdrawal" is certainly understood as being return from customer by Tesco as in EPW = emergency product withdrawal from their supply chain.
Perhaps I should clarify here customer = retailer or B2B customer, consumer = person who is going to eat the product.
Hi GMO
I suppose the interpretation of these two terms might depend on your position in the supply chain and the fact we are not supplying product directly to the supermarkets?
Looking again however at clause 3.12.6 it does refer to “product recalls initiated by the brand owner”, so perhaps my interpretation is not correct. Fortunately for me we have a single Withdrawal & Recall procedure within our quality management system as the process involved would be the same regardless of the reason behind any incident and where our product is in the supply chain at the time of the incident.
As an aside, I have noticed that some of our customers are now asking for copies of findings from internal auditing of our traceability and recall capabilities. To date I have received no feedback (good or bad) on what I have sent, which I suppose must be a good thing!
Nice one Tony.