Food Safety Standard

Conducting a Food Recall

When to recall Food Product:

A problem is identified and assessed

A food business may be informed of a problem with any of its food products via the following mechanisms:

in-house testing indicates that there may be a potential problem with a particular food product or batch
customer / consumer complaints / feedback (e.g. phone call or letter from a customer or wholesaler informing the business of a potential problem)
a supplier of a raw material that is used by the company in making its food products informs the business that there is a problem with an ingredient
government authorities, such as health departments, local councils, or the police, indicate that there may be a problem with a particular food product

Such problems may include:

microbiological results outside of acceptable limits
chemical contamination
the presence of foreign matter
labelling errors
packaging defects
under-processing

It is important that all necessary information about the nature of the problem/hazard is obtained so that an assessment can be made to establish whether the food product is unsafe and recall action is required. Expert advice may be needed to assess the risk.

The sponsor may, for example, convene a recall committee with representatives from key areas (technical, manufacturing, warehousing and distribution, etc.) to help assess the problem and the appropriate course of action. The decision may be made in consultation between the sponsor and the Home State or Territory Action Officer.

Sponsors should also consider the possibility of the same problem occurring in different package sizes of the same line, in food product with a different batch number or use by date, in a different food product line altogether, or same or similar food product packaged under a generic label.

If the problem is found to be linked to one or more raw materials supplied to the sponsor, then the supplier of the raw materials and their customers should also be notified and the affected supply chain alerted.

Food product tampering/extortion:

Food products can be the target of acts of deliberate contamination, which may be accompanied by extortion demands or may be intended to cause adverse publicity or economic harm to a supplier or retailer. These acts may occur at any stage during the manufacturing process, during transport or at the point of sale. When this occurs the Police and State or Territory authority must be contacted immediately. All subsequent actions are to be taken in consultation with, and on advice from the Police and State or Territory authority.

Recall or withdrawal:

An assessment of the problem will determine what action is required. A recall is required when there is a reasonable possibility that use or consumption of the food could cause adverse health consequences.

If the problem with a food product is deemed to be a quality defect only, the food product may be withdrawn from sale. A food product may be withdrawn as a precautionary measure pending further investigation of the problem.

The Recall Processes:

Once the decision to recall a product has been made, there are three primary objectives:

stop the distribution and sale of the affected product as soon as possible
inform the government authorities (all recalls) and the public (consumer level recalls only) of the problem
effectively and efficiently remove from the market place any product which is potentially unsafe

The sponsor has prime responsibility for implementing the recall and for ensuring compliance with its recall procedure.

The key steps in conducting a successful recall are:

obtain and consolidate all necessary information about the food product
determine the level of recall required
notify relevant parties
retrieve the food product from the market place
dispose of the food product
report on the recall, including the action taken to prevent a recurrence of the problem

Information requirements:

It is important that the food product can be properly identified and traced in order to retrieve it from the market place. The sponsor should be able to provide the following information in order to conduct an effective recall:

nature of the problem
brand name and description of the food product, including package size and type of packaging
use by or best before date
lot identification (batch or serial number)
quantity of the batch manufactured and the date and amount released
quantity of the affected food product that can be accounted for
distribution within Australia (including a distribution list and the types of premises at which the food product is likely to be sold)
overseas distribution (if applicable)
importer information (for imported product)

It may also be useful to provide a photo or other image of the food product to help identify it.

Level of recall:

Depending on the extent of distribution of the food product, the recall action initiated by the sponsor will be either a trade level recall or a consumer level recall. In determining the recall level, the principal factors to be considered are:

the channels by which the food product has been distributed (e.g., food product destined only for catering purposes)
the extent of distribution (e.g., has the food product reached the retail chain and consumers)

It is recommended that the level of recall is determined in consultation with the Home State or Territory Action Officer.

Notify relevant parties:

The relevant parties to notify of a recall include:

government authorities
the distribution network/chain, trade customers, retailers
the public (in the case of a consumer level recall)
food industry organizations

Retrieval of the food product:

Food products may be recovered by returns to retailers, returns via distribution chains or direct returns from consumers.

The recovered food product may be returned to a central site or, in the case of a widely distributed food product, to major recovery sites. Some major retailers will retrieve and dispose of the stock at store level. The recovered food product must be kept separate and clearly identified in some way.

Accurate records should be kept of the amount of recovered food product and the lot identification details of that food product.

Food product disposal:

Food that is subject to recall must be disposed of in accordance with the requirements of regulation

Recalled food product that is being held must be separated from other food and clearly identified. The sponsor should determine the method of food product disposal in conjunction with the Home State or Territory Action Officer. Options for the recalled food product may include:

destruction or other use so that the food product cannot be used for human consumption. A local Environmental Health Officer may be asked to oversee the destruction of the recalled food product and to issue a statement certifying that the food product has been destroyed to the satisfaction of the relevant State or Territory authority
further processing to ensure the safety and suitability of the food product (such as re-labelling)
ascertaining that the returned food product is safe and suitable (e.g., physical inspection in the case of reported faulty vacuum seals)

Post recall reporting:

The effectiveness of a recall can be assessed on the basis of the amount of food product returned as a proportion of the amount of food product that left the sponsor, taking into account the retail turnover of the food product.

In addition to assessing the effectiveness of a recall, the sponsor should investigate the reason for the recall and take corrective action to prevent a recurrence of the problem.

Food Recall Checklist:

The checklist below outlines the requirements of the sponsor when a problem is identified with one of their food products.

nominate the person/team to assess the problem
contact the Home State/Territory to help determine the appropriate course of action
if a recall is to occur, comply with the food recall system. Key steps include:
- identify which batches of food product are affected
- isolate stock that is still with the sponsor (to minimise further distribution of the affected product)
- contact Food Safety Authority-FSANZ (who will coordinate the recall)
- contact distributors
- compile a distribution list, including the types of premises at which the food product is likely to be sold
- notify the commonwealth minister responsible for consumer affairs in writing within 2 days of initiating the recall
- inform the public (for consumer recalls only)
- arrange for the isolation, storage and disposal of affected stock
- check the effectiveness of the recall
- implement a course of action to prevent a recurrence of the problem
- prepare an interim and final report for FSANZ