Mock Recall Procedures

What is a Food Recall?

Food producers use many controls to ensure the safety of their products. Despite their best efforts, however, sometimes unsafe food products, or those that do not meet legislative requirements, make their way into the marketplace. When an unsafe or violative food product has left the control of the manufacturer/distributor, it must be removed from the market. This process of removing the product is called a recall.

What can Prompt a Recall?

• Allergens
• Bacterial Contamination
• Chemical Contamination
• Communicable Diseases
• Undeclared Ingredients
• Foreign Objects
• Packaging Defects
• Misbranding
• Illnesses identified by the State Health Dept or CDC
• Tampering or tampering threats
• In-house sabotage
• Supplier’s notification
• Real or fraudulent consumer claims

Decision to Recall:

• A recall, unless otherwise determined by law, is a voluntary action
• The officers and employees of a food company have a legal and ethical responsibility to ensure that their products are safe, sanitary and accurately labelled
• Protect Brand, Protect Confidence of Consumer, Protect Employees and shareholders and Protect Future of the Company

Government Agencies Which Deal with Food Safety Issues:

• FSSAI (Food Safety and Standard Authority of India)
• FDA (Food and Drug Administration)
• USDA (United States Department of Agriculture)
• FSIS (Food Safety and Inspection Service)
• APHIS (Animal and Plant Health Inspection Services)
• State and Local Agencies
• EPA (Environmental Protection Agency)
• FBI (Federal Bureau of Investigation)

Regulatory Basis of Food Recalls:

• Federal agencies such as the FDA or FSIS do not “order” recalls – they “request” recalls
• Federal agencies can take stringent actions when a food product proposes a significant health risk and a manufacturer does not launch a voluntary recall or the voluntary action is ineffective
• If company initiated recall, everything possible must be done to put the recall into motion promptly and not wait for the regulatory agency to review or approve the recall strategy
• It is in the best interest of a food manufacturer to fully cooperate with federal agencies.
• A food manufacturer should initiate a recall when requested by a federal agency although it is not required
• Before an agency formally requests a recall, it has evidence capable of supporting legal action

Recall Classification:

Class I

A situation where serious adverse health consequences (possibly even fatal) may result if the product is consumed. A public alert is usually issued.

Class II

A situation where a health hazard might exist but the probability is remote. A public alert may be issued.

Class III

A situation where the consumption of the product is not likely to cause health problems. A public alert is not usually issued.

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