Notification of CB and SQFI when Recall is not "Public"

I posted the following on an old thread but it promptly got buried:

SQF 7.2: Text of 5.3 states "event that requires public notification."  I have heard of a recall where public notification was not required, that is the material in question was shipped to a customer distribution site and was controlled at that point. None entered commerce.

Question is, in such a case is it required to notifiy SQFI and CB?  Thoughts?

Hi RMAV,

The situation you are referring to is a withdrawal and as such you will not need to follow recall notification procedures:

SQF Code Edition 7.2 - 2.6.3 Implementation Guidance

What does it mean?
A product recall applies when a product is found to be unsafe or otherwise in breach of regulatory requirements and is withdrawn from public sale and the consumer market is advised not to use or consume that product. Recalls may be mandatory (i.e., initiated by a regulator), retailer driven, or voluntary (i.e., initiated by the supplier).
A product withdrawal applies when a dispatched product is found not to meet safety or quality requirements, is deemed not suitable for sale and is withdrawn from the distribution chain before it has reached the consumer.

What do I have to do?
The SQFI and the supplier’s certification body (CB) must be included on the communication list. The supplier is required to notify the CB and SQFI in writing within 24 hours of a food safety incident of a public nature (i.e. requiring public notification)or a product recall for any reason.

Regards,

Tony

In that particular case the FDA notified the firm that it was considered it a [class I/II] recall but, according to the FDA, a press release/recall alert was not necessary, but would be published in a weekly report that is accessible to the public -if they look for it.

I read the guidance but missed your underlined above, that according to the SQF definition, the action was a withdrawal.

As I read the code, and this is just my impression, an intent of 5.3 (responsibilities) and 2.6.3 is that SQFI and the CB wants to be notified of anything public.  While this recall was not "public," and had not entered commerce it could be argued it became public when it was published in the FDA report.  The firm, to stay on the safe side, elected to notify the CB and SQFI once it was published.

Any other thoughts on this appreciated, this one is a little gray to me.

You do need to notify CB /SQFI before the 24hrs is due but put it in the notification that this is not published yet. All they will do is send you a questionnaire to complete

 if you miss the 24hr  deadline its an automatic major NC and you dont want to go there.

Hi,

When you notify your CB and SQFI, you should also provide them with an investigation summary (report) outlining the steps you have taken to facilitate the recall/withdrawal. It doesn't have to be complete if the investigation takes more than 24hrs, but it should be provided in the communication.

Thanks.
amppyr