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SQFI 2.6.3.4 - Recall Notification

SQF 9.0 Recall

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ArjunBhusal12

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Posted 17 February 2022 - 03:32 PM

Auditor has raised a NC for this code indicating we missed to notify the CB and SQF for a recall that was not initiated by us based on the code below. 

 

2.6.3.4 SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety

event that requires public notification. SQFI shall be notified atfoodsafetycrisis@sqfi.com.
 
Our point is since it is not initiated by us we don't have to notify and since the product we had received went out as it is to customers. 
Our record shows that we were able to identify and notify all the customers. 
 
Is there a still point for us to appeal? We only had one major NCs costing us 5 points. 
 
Please let your opinions. 
 
Thank you! 
 


Setanta

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Posted 17 February 2022 - 04:03 PM

Who did originate the recall?


-Setanta         

 

 

 


olenazh

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Posted 17 February 2022 - 04:09 PM

Hi Arjun, welcome to our forum! You're right: as a recall was initiated by other party it was their responsibility to notify whatever regulatory bodies. Did your customer inform you of the recall and its reason? What do you mean by "the product we had received went out as it is to customers"? You are not the manufacturer of that product?



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ArjunBhusal12

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Posted 17 February 2022 - 04:17 PM

Thank you for your response. 

We are not manufactures of that product.  Recall was initiated by a supplier who supplied to our vendor and we received the product from that particular vendor. 

As a distributor, we distributed that product to our customers. Our vendor notified that product we received from them was impacted by recall. 

Also, the recall was already made public by the supplier and FDA. 



olenazh

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Posted 17 February 2022 - 04:22 PM

So, the requirement of 2.6.3.4 is related to the vendor, not you as a distributor.



Scampi

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Posted 17 February 2022 - 04:52 PM

Is YOUR site the one that is certified? if so than you did not fulfill the requirements of the element, you had an obligation under the code to notify SQF. The code does not stipulate WHERE/WHO the recall originated--hence the word "identification"

 

Sorry, but I think you will not win this one

 

2.6.3.4 SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety event that requires public notification. SQFI shall be notified at foodsafetycrisis@sqfi.com.

Please stop referring to me as Sir/sirs


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olenazh

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Posted 17 February 2022 - 05:02 PM

 

Is YOUR site the one that is certified? if so than you did not fulfill the requirements of the element, you had an obligation under the code to notify SQF. The code does not stipulate WHERE/WHO the recall originated--hence the word "identification"

 

Sorry, but I think you will not win this one

 

2.6.3.4 SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety event that requires public notification. SQFI shall be notified at foodsafetycrisis@sqfi.com.

 

What if the Vendor is also GFSI certified, SQF? Whose fault than is it?



ArjunBhusal12

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Posted 17 February 2022 - 05:03 PM

Thank you everyone for your input. 



BigAlittlea

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Posted 17 February 2022 - 05:28 PM

Stated in Food Safety Code: Storage and Distribution Ed. 9 Element Code 2.6.3.4 " SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety event that has been initiated  by the site requires public notification. SQFI shall be notified at foodsafetycrisis@sqfi.com



Brendan Triplett

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Posted 17 February 2022 - 05:43 PM

I wonder if this is one of those instances where the manufacturer would make the call since they are SQF and the distributor would also make the call, confirming the original call by the manufacturer and creating a checks and balances type of deal.

 

Cheers!


Vice President and SQF Practitioner in Pennsylvania
Brendan Triplett


Brendan Triplett

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Posted 17 February 2022 - 05:44 PM

Stated in Food Safety Code: Storage and Distribution Ed. 9 Element Code 2.6.3.4 " SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety event that has been initiated  by the site requires public notification. SQFI shall be notified at foodsafetycrisis@sqfi.com

 

Interesting point though, if they are initiating the recall then it should be them.  You are not initiating the call, you are simply reacting the the call they initiated and enacting your product trace and recall program.

 

Cheers!


Vice President and SQF Practitioner in Pennsylvania
Brendan Triplett


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ArjunBhusal12

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Posted 17 February 2022 - 05:55 PM

yes it is a very interesting situation. 

One of my food safety professor said we have to notify only if we were using that product to manufacture something, which we didn't. 

Also, the use of language "identification" on code for food safety event might validate auditor POV. 



Scampi

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Posted 17 February 2022 - 06:03 PM

What if the Vendor is also GFSI certified, SQF? Whose fault than is it?

 The poster only needs to worry about their site, the vendor ALSO needs to report to their CB and SQFI, but it is not the posters place to verify that

 

The entire point of this to ensure recall process' are followed properly, one issue does not negate the other


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Scampi

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Posted 17 February 2022 - 06:46 PM

yes it is a very interesting situation. 

One of my food safety professor said we have to notify only if we were using that product to manufacture something, which we didn't. 

Also, the use of language "identification" on code for food safety event might validate auditor POV. 

Your professor needs to go back to school

 

https://www.fda.gov/...123664/download


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SQFconsultant

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Posted 18 February 2022 - 12:58 PM

At best a curtesy contact to cb and SQF may have been warrented but a full blown formal notification was not needed nor called for..
Challenhe this finding.


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