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Management of Incidents, Product Withdrawal and Product Recall

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ChristinaD06

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Posted 12 October 2016 - 11:31 AM

In regards to section 3.11 of the standard does anyone have a decision tree they could share to determine if the incident requires a recall or withdrawal?

Many thanks

Christina


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FurFarmandFork

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Posted 13 October 2016 - 01:53 PM

Hard to say for UK. The question of recall is included in my corrective and preventative action SOP. These criteria are used:

 

1. Identify source of the issue.

2. Is there a potential for additional product to be affected?

No-Dispose of implicated material and document investigation. 


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FurFarmandFork

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Posted 13 October 2016 - 02:00 PM

Sorry, accidentally posted halfway through writing.

 

The question of recall is included in my corrective and preventative action SOP. This flow is used, sorry for the poor format.

 

1. Identify source of the issue.

2. Is there a potential for additional product to be affected?

No-Dispose of implicated material and document investigation. STOP

 

3. Yes- Is the material all still in company control?

Yes-Place affected material on hold for disposal or rework. STOP

 

4. No-Does the defect pose a food safety risk to consumers?

Yes-Initiate recall (reference recall procedure)

 

5. No-Does the material have a defect that would be subject to legal action by regulatory agencies?

Yes-Initiate recall

 

6. No-Does the material have a defect that would be unacceptable to customers?

No-Dispose of implicated material and document investigation. STOP

 

7. Yes-Is the defect likely to be present at a frequency that does not meet yours or your customer's quality specifications? (E.g. number of torn or unusable packages in a shipment)

No-Dispose of implicated material and document investigation. STOP

 

8. Yes-Initiate product withdrawal.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

ChristinaD06

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Posted 13 October 2016 - 02:05 PM

Thank you that's really helpful. We are a retail site not manufacturing but I am sure I can adapt the above to suit. Thanks Christina


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FurFarmandFork

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Posted 13 October 2016 - 03:05 PM

Hi Christina,

 

You're welcome. I agree the above flow should still work fine in your situation, you'd just have different examples. Some samples below I just made up with "investigation details":

 

Fake incident: Customer brought back a raw chicken that smelled like bleach.

 

1. Identify source of the issue. Various potential sources identified in the investigation listed at the stop and decision points below

2. Is there a potential for additional product to be affected? 

No-Dispose of implicated material and document investigation. STOP Customer realized after thinking about it that their dishes had bleach on them.

 

3. Yes Discovered that a new employee used bleach on chicken cooler without proper rinsing night before.- Is the material all still in company control? 

Yes-Place affected material on hold for disposal or rework. STOP This was the only chicken purchased from the cooler that day. All other affected food is still here.

 

4. No Multiple chickens were purchased from the cooler.-Does the defect pose a food safety risk to consumers?

Yes-Initiate recall (reference recall procedure) Bleach was undiluted and potentially hazardous.

 

5. No Bleach was at a dilution safe for consumption.-Does the material have a defect that would be subject to legal action by regulatory agencies?

Yes-Initiate recall The chicken contained a splash claim on the label "No bleach used on equipment!"

 

6. No This is a permissible food additive at a safe level.-Does the material have a defect that would be unacceptable to customers?

No-Dispose of implicated material and document investigation. STOP The chicken doesn't smell like bleach to 9/10 employees, and only super-smellers would notice it, and only before cooking.

 

7. Yes The chicken has a strong bleach smell that will ruin its flavor .-Is the defect likely to be present at a frequency that does not meet yours or your customer's quality specifications? (E.g. number of torn or unusable packages in a shipment)

No-Dispose of implicated material and document investigation. STOP Only one chicken sitting in a well in the cooler contacted the bleached surface, the customer knocked it out of the basket into the bottom of the cooler, all others were in a basket and had no smell and it is unlikely that any other customers also knocked their chicken out of the basket.

 

8. Yes multiple chickens in the cooler smell like bleach -Initiate product withdrawal.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

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ChristinaD06

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Posted 13 October 2016 - 04:48 PM

Wow! Amazing so helpful. Thanks


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