Glass found in raw material...unsure whether to recall previously packed product
Hi! Our facility packages dried herbs and one of our packagers found a small piece of glass in the box of raw material. All of our material is hand packed and inspected as it is packed and the glass was found when a new box of material was opened (confirmed that the glass did not come from our facility and was from the supplier farm we assume). The entire contents of the box will be disposed of, however other boxes from the same lot had previously been packaged and sold to customers over 6 months ago. We feel pretty confident that the issue is isolated to the one box since we hand pack everything and inspect as we pack so we are not sure a recall is necessary for the previously packed items from the same raw material lot. Can this be supported by anything in SQF, or in this situation is a recall always necessary? Thank you for any help!
Hi! Our facility packages dried herbs and one of our packagers found a small piece of glass in the box of raw material. All of our material is hand packed and inspected as it is packed and the glass was found when a new box of material was opened (confirmed that the glass did not come from our facility and was from the supplier farm we assume). The entire contents of the box will be disposed of, however other boxes from the same lot had previously been packaged and sold to customers over 6 months ago. We feel pretty confident that the issue is isolated to the one box since we hand pack everything and inspect as we pack so we are not sure a recall is necessary for the previously packed items from the same raw material lot. Can this be supported by anything in SQF, or in this situation is a recall always necessary?
Thank you for any help!
1st Question -
So what is the relevant Regulatory requirement/action for this defect (if any) ?
eg this was apparently NZ situation in 2015 -
Glass
Consider the type and size of glass fragments present.
Where glass fragments are likely to include shards or splinters general the MPI practice has been to require recall, irrespective of the likely size of the glass pieces.
Some glass is designed to shatter into rounded pieces rather than to produce sharp fragments. In this case the size of the pieces may determine whether a food safety hazard exists (see ‘general’).
You've got to answer to the regulatory body FIRST AND FOREMOST in this situation. SQF is secondary
If you're shipping out of province and/or internationally your governed by CFIA and must follow their procedure. If you only sell within your own province, you must follow the provincial regulations (which are almost a mirror image of the federal ones)
I'm going to say you should recall your product. Just because you hand pack does not mean anything when it comes to glass shards.
And if nothing else, just imagine what it is going to cost the company if you don't and someone gets hurt..................
What did your investigation into the source show??????????? Are your suppliers CanadaGap certified?
https://inspection.c...5/1535516168226 Step 3: Identify all food to be recalledIn addition to the food directly affected, determine if:
- any other sizes, brands, or codes or unique identifiers of the same food are affected
- any other food is affected
If this is the case, include this food in your recall.
Tips- Have a traceability system that will allow you to be best prepared for an effective recall. Refer to Part 5 of the SFCR for the regulatory requirements related to traceability.
- Recalls can be triggered by ingredients that were incorporated into your food. To better target affected foods, consider documenting the lot codes or unique identifiers of each ingredient that you incorporate into your food.
- Recalls may also be caused by unsafe packaging material. Ensure you can link packaging materials to the food lot codes you are responsible for. Consider documenting and implementing the following practices:
- Associate packaging materials to their suppliers
- Associate packaging materials to your food lot codes
100% agree with Scampi that SQF isn't what you should be focusing on. You want to make sure you follow your governmental food law to the letter. You will have to alert SQF in the event you find you have to recall product, but they aren't going to have anything in the code that could support a decision to avoid a recall. They wouldn't be foolish enough to open themselves up to liability like that.
The CFIA decision procedure appears to basically involve 2 evaluation stages.
(1) Risk Assessment
(2) Use of Result of (1) to determine the necessity of a Recall (Class 1 to 3)
The Overall Procedure is summarised in link below but examples of the precise details of the actual assessment(s) (and particularly with respect to "glass") seem so far to be "elusive" (to me).
https://inspection.c...5/1332207914673
PS - there are lots of issued examples of Alerts for Recalls due "Extraneous Material Hazard" if one likes to Google.
PPS - Note that criteria for "hazardous" glass are discussed in the CFIA Hazard Database