When to alert certification body about a recall?
Hello all,
When performing a recall you need to alert your certification body.
but when is a recall an actual recall?
We have a product with a problem with pesticide. The product currently in stock at our customers (Industry not consumers or retail) needs to be blocked and must be send back to us or destroyed.
Is this already a recall or is this only a recall when the final consumer must be informed?
This would be a product withdrawal, since you're not getting product back from the consumer level - see the glossary on page 110 of the standard.
You've posted this in the BRC section of the forum, so I'd assume you're looking at whether 3.11.4 applies in this situation?
The Interpretation Guide doesn't actually provide much detail beyond that included in the clause in the standard itself - i.e. a recall, regulatory enforcement action, or a "significant food safety incident".
In your position I think I'd call the certification body to get their take on it - seems better to do this and be told it's not necessary, than to not do it and then have it come up in an audit and land you with a non-conformance IMO.
A client recently asked us this and it was the same situation (with food, not pesticides) where a withdrawal would be made.
I said there are two ways + 1 to look at it, if we go strictly by code, the answer is NO contact is needed.
But... if there is a tiny tiny possibility of word of this withdrawal getting out to the public/media the answer is YES
Simple withdrawals many times end up being labeled by others as recalls - the term recall is a real sticky wicket.
So, with all things considered I suggested they make contact to explain the non-recall as a precaution.
Thank you for the replies.
Just to be sure I notified the control body
Before our last BRC audit we'd had one or two withdrawls from food industry costumers and one recall when product had potentially reached costumers (the goods where delivered to stores).
We didn't notify certification body for the withdrawls but for the recall. According to our auditor this was correct procedure.