Product recall and crisis management
Education Module 12 May 2018
The FIAAA advocates and promotes the safe use of feed ingredients. FIAAA members demonstrate their commitment by achieving and maintaining certification to the FIAAA Code of Practice (COP).
Adherence to the COP assures customers of the safety and quality of certified FIAAA members’ products.
Nevertheless, there is risk in any operation so the FIAAA COP includes a requirement for written recall and crisis management procedures.
A product that is found to be unsafe or not to meet specifications may pose a risk to animals, humans, the environment and both domestic and export markets. The FIAAA expects its members to exercise rigor in adhering to the COP requirements for recall and crisis management.
Continuous improvement is an expectation in any quality system. There is some good guidance in the public domain on recall procedures. The following may provide useful information for your next review of procedures around recall and crisis management.
Who do you inform?
A recall procedure will ensure you have the steps in place to inform customers promptly. There are also requirements to inform the competent or regulatory authorities. Your organisation must determine the authorities relevant to the business and products. At a minimum these should be:
- The department of agriculture in your state and other states impacted
- The Chief Veterinary officer in relevant states.
Others may be:
- The federal Department of Agriculture and Water Resources (DAWR) would be relevant if the product doesn’t comply with specifications and declarations made for an import permit
- The APVMA for registered products
- Safe work Australia or the workplace authority in your state if the issue may impact worker safety
- The EPA may need to be informed in some circumstances, either at the federal, state or local level.
- Have you conducted a mock recall to ensure the efficacy of your procedure?
- Have you checked the currency of contacts in your ‘who to inform’ list?
- Does your internal audit program include recalls and crisis management?
- Where do the factors that may lead to a recall sit on your risk matrix?
- Does upper management have oversight and responsibility for recalls and crisis management?
Extract from the FIAAA Code of Practice
A formal recall procedure shall be documented so that customers can be informed immediately of any irregularities that may compromise feed safety.
The recall procedure shall be regularly reviewed to ensure conformance with the quality manual and regulatory requirements and the supplier’s organization.
The recall procedure shall include requirements to:
9.1.1 define and allocate responsibility for the recall process;
9.1.2 identify each batch of non-conforming product including consequences to other product batches or raw materials throughout the entire process.
9.1.3 identify the destination of affected batches;
9.1.4 notify customers of affected batches and coordinate product return;
9.1.5 describe procedures for the handling and reassessment and/or disposal of recalled product(s) including segregation from other products and materials;
9.1.6 maintain records of product recall(s) and components from production and/or distribution to the affected customers;
Simultaneously with the above listed action points, it is important to limit recurrence by:
9.1.7 ensuring immediate corrective and preventive actions are undertaken;
9.1.8 verifying that corrective and preventative actions are effective.
Feed additive and premixture businesses may also remove products from the market for reasons other than food safety; these cases should be handled in the same manner described here.
The recall procedure shall be tested at least annually to ensure functionality. Such tests shall be documented and evaluated for improvements.
9.2 Crisis Management
If a feed business supplier considers or has reason to believe that a feed which it has been imported, produced, processed, manufactured or distributed does not satisfy the feed safety requirements it shall immediately initiate procedures to recall the feed in question from the market and inform the competent authorities thereof.
9.2.1 The crisis management procedure shall be documented
9.2.2 Responsibility shall be defined for notifying customers and regulatory authorities