Product recall‖ means action taken to remove a marketed food product from distribution, sale, and consumption that may pose a safety hazard to consumers. This means that the manufacturer has to ask for a return of a batch or the entire run of a particular product because of safety concerns. Product recall is usually very expensive as it requires the manufacturer to replace the recalled product or pay for any damage that could have occurred because of use of a defective product.
A food product is recalled so that the manufacturer can take corrective action needed to protect consumers from a contaminated, adulterated, or misbranded product. A corrective action usually involves destroying replacing or altering the product. The type of recall of a product depends on the company‘s food safety policies, ethical understanding, regulatory requirements, and financial constraints. A product recall is of two types
- A voluntary recall is based on the decision of the management of a manufacturing company to recall the product. A product recall initiated by the manufacturers themselves limits the liability if the manufacturer has been negligent. It prevents further damage to the brand and improves the trust in the manufacturer to some extent… If the recall is conducted smoothly then it can save the company from negative publicity.
- Recall can be initiated by a government agency responsible for the particular product category in which case it will request the company to recall the product. The government agency can force the company to recall potentially misleading and/or hazardous product from distribution and marketing.
Food product recall according to Section 28 of the FSSA
Involuntary food product recall a manufacturer, either of its own through any other sources viz. wholesaler, distributor, retailer, exporter, importer, consumer, media etc., coming to know that any of its products are unsafe or deficient violating provisions of the Act and Rules, & Regulations made thereunder, may initiate a recall. In such situations, the manufacturer is required to submit a recall alert notification to the Competent Authority. To ensure speedy communication, such alert can be sent by Fax, e-mail, On-line and/or by post.
If the recall is government initiated then the Food Authority may direct the manufacturer to initiate a recall if a food product manufactured and distributed by him poses a health hazard or is in violation and the firm has not initiated a recall on its own. Seizure or other court action may be taken when a firm refuses to undertake a recall directed by the Authority or if the Food Authority has sufficient reasons to believe that
- the recall would not be effective,
- determines that a recall is ineffective
- discovers that violation is continuing
The cost incurred by the Food Authority for carrying out such actions will be recovered from the firm responsible for such violation.
Purpose and goals of the recall plan
A product recall cannot be worked out hastily when the crisis strikes. It should be a part of the company’s FSMS programme if the manufacturer wants to lessen the impact of the product recall. A recall is undesirable because besides being expensive it brings about negative publicity. However, if a recall is required then is important to be ready for the recall and it is in the company’s best interest to complete it as quickly as possible. If the recall needs to happen smoothly and quickly there has to be a recall plan in place. For this, the management of the manufacturing company has to be a part of the recall plan and team so that the recall is effective. This will allow the company to avoid or improve on negative publicity. A plan will allow the company to cover the expenses that a product recall will require. A recall plan should be able to achieve the following goals
- Protect consumer health
- Comply with existing FSSA rules and regulations
- Minimize the cost of the recall
- Regain and improve the company‘s reputation
According to FSSAI “all food businesses engaged in the wholesale supply, manufacture or importation of food regulated by Food Authority must have an up-to-date recall plan except food retailers unless they are also engaged in the wholesale supply, manufacture or importation of food. Food businesses within the food service sector such as restaurants, caterers, and takeaways are exempted to have recall plan unless they are running multi-outlet food business chains having integrated manufacturing and distribution network.”
A Successful Recall Process
- A successful recall process depends on the planning of the recall management well before a problem occurs.
- Time is an important factor and the sooner the recall is initiated the less harm it will cause and lessen negative publicity
- Communication needs to be effective during a recall so that everyone in the product distribution channels can act on the instructions. Public notification about the recall through press releases and specialized media is also an important aspect of a recall process.
- Post-recall assessment is as important to determine if the recall has been effective and to improve on any shortfalls in any future recalls if they should occur.
Management’s responsibility for food product recall
Without the involvement of the management in the product recall, the recall procedure will not be swift or effective or completed in a timely manner.
The top management of the company should
- appoint personnel having the authority to initiate a recall and personnel responsible for executing the recall
- establish and maintain a documented procedure for notification to relevant interested parties (e.g. statutory and regulatory authorities, customers and/or consumers),
- handle recalled products as well as affected batches of the products still in stock, and the sequence of actions to be taken
All recalled products need to be kept securely or held under supervision until
- they are destroyed
- used for purposes other than originally intended
- determined to be safe for the same (or other) intended use
- reprocessed in a manner to ensure they become safe
The management must be made fully aware of the causes and the extent and result of a product recall. Any recall must be recorded and reported to top management. This will provide an input to the management so decisions can be taken to prevent recurrence. The company must verify and record the effectiveness of the recall programme through the use of mock recall programmes.