Insect Contamination Complaint dried herbs and spices

Hello, we sell dried herbs and spices and we just had a customer report that they found live insects in product from us. We still have some of the raw material in stock and when inspected, one of 5 boxes was found to have visible insects. We have segregated all material and will be refunding the customer who complained. We are in the process of investigating but believe the material has insect eggs from the supplier (boxes were sealed and not opened in our facility before the inspection so we do not think this is an issue in our facility). Everything has been pulled which contained this material, however there is some product that had already gone out to customers. 

We are a small facility and hand pack our products, so chances are the product that went out were made from a box with no issues, as we only found insects in one of the 5 remaining boxes, also our staff is well trained and would report any visible issues during packaging. However, should we still issue a recall for those items? And if we did issue a recall, do we still notify CFIA, SQF and our CB if its not a food safety issue

There are different opinions with the staff here as to whether a recall is necessary since it is not a food safety issue. Anyone have any insight?

Yes, you still need to notify all 3

As this product is "unfit" for human consumption (e.g. live insects or even carcasses) you are obligated to notify CFIA of recall as per SFCR

https://inspection.c...5/1535516168226

https://laws-lois.ju...6.html#h-844376

Marginal note:Investigation

• 82 (1) An operator who suspects on reasonable grounds that a food presents a risk of injury to human health or does not meet the requirements of the Act or these Regulations must immediately investigate the matter.

• Marginal note:Notification and mitigation of risk

  (2) If the investigation establishes that the food presents a risk of injury to human health, the operator must immediately notify the Minister and immediately take action to mitigate the risk.

Marginal note:Complaints procedure

• 83 (1) An operator must prepare, keep and maintain a document that sets out a procedure for receiving, investigating and responding to complaints that are received in relation to a food.

• Marginal note:Complaints

  (2) If a complaint is received, the operator must implement the procedure and prepare a document that sets out the details of the complaint, the results of the investigation and the actions taken based on those results and keep it for two years after the day on which the actions are completed.

Hello, we sell dried herbs and spices...

There are different opinions with the staff here as to whether a recall is necessary since it is not a food safety issue. Anyone have any insight?

I'm curious how it was concluded that live insects in your ingredients are an acceptable safety risk, when you have evidence they are reaching your customers (ie. no form of CCP that would render them harmless)?

Does your product carry a for-further-processing statement like raw flour would, indicating the customer/consumer must perform a lethality treatment?

I usually like to throw out the "acceptable bug parts" literature from the FDA when it comes to insect complaints, but I think any argument there goes out the window when they're still alive...

We advise initiating a product recall immediately. This will enable to promptly remove any affected units from the market and safeguard customers from potential harm. Additionally, it will demonstrate a commitment to rectifying the situation and restoring trust in the brand.

We understand that a product recall can pose challenges and disruptions to the normal production and distribution processes.