Definition of Recall Plan:

Recall actions are taken by a company/firm to remove products of the market; from manufacturers, distributors and/or consumers. Recalls may be conduct by firms’ own initiative or by AVA request/statutory authority.

Objectives of a Recall Plan:

To locate and terminate the sale and distribution of all defective products in the markets as soon as possible.
To effectively and efficiently remove defective products from the distribution chains and from possession of consumers as quickly as possible.
To inform statutory authorities and the public about the recall in a timely and understandable manner.

Difference between Product Withdrawal and Product Recall:

Product Withdrawal is due to:
Quality defects in product (e.g. colour, texture),
Inaccurate weight; underweighted,
Labeling irregularities that do not pose a potential risk to public health or safety.

Withdrawals of goods from distribution lines are done as a precaution as it does not risk public health or safety. However, if risks exist, product recall must be established.

Product Recall is due to:
Consumption of such products will cause adverse health consequences or even death (e.g. Listeria Monocytogenes, Samonella, Clostridium botulinum, toxins or other harmful foreign particles.)
Serious labeling errors that could pose potential risk to public health and safety (e.g. not declaring allergen, insufficient cooking time and temperature.)

Corrective actions include:
Permanently remove unsafe products from the market.
Temporary removal of unsafe products from the market; return to the market after rectifications.

Reporting Criteria for Recall Plan:

Each must inform Commission immediately if company receives information on delivered products which;
Fails to meet Consumer Product Safety or any banning regulations.
Contains substances which are of substantial hazard to consumers.
Creates unreasonable risks of injury or even death.
Fails to comply with regulations.

Steps in conducting a proper Product Recall:

1. Convening of a recall committee;
2. Hazard/Risk assessment;
3. Determine the level of the recall;
4. Determine who should be notified of the recall;
5. Determine the mechanics of notification and recovery;
6. Post recalls reports.

Convening a Recall Committee:

Recall committee involved should comprise of senior management team members whose expertises are in this field. Example of a Recall Committee:

• Recall coordinator (ideally the firm’s senior technical executive);
• Managing director;
• Head of public relations;
• Head of manufacturing;
• Head of warehousing and distribution;
• Head of purchasing;
• Head of sales and/or marketing; and
• Firm’s legal representative.

Hazard/Risk Assessment

Information obtained has to be carefully analyzed before any decision is made regarding the recall plan. This information is crucial in a proper recall plan.

The problem
• Nature of the problem (type of hazard and assessment of risk); and
• Results of tests and other investigations on suspect sample or other samples.

The product
• Product name and description, including package size and type;
• Lot identification (batch or serial number);
• ‘Use-by Date’, ‘Packed on’ date, or ‘Best Before’ date where relevant (may also be the lot identification);
• Company contact telephone number (including after hours number.);
• Quantity of the batch, date and amount released;
• Distribution within country; and
• Overseas distribution of any exported product.

Other relevant information
• Name and telephone number of the person reporting the problem;
• Date of the report;
• Number of similar reports received (eg. customer complaints);
• Availability for investigation of suspect sample or other samples;
• Action proposed by the firm; and
• Proposed recall level.

Level of Recall Plan:

There are 2 kinds of Recall plans; Trade Recall and Consumer Recall plans.

Trade recall

This involves recovery of affected products from distribution centres, wholesalers and also involves recovery of products from hospitals, restaurants and other major catering establishments, as well as outlets that sell food manufactured for immediate consumption.

Consumer recall

This is the most extensive type of recall. It involves recovery of affected products from both production and distribution networks. It also includes retrieving of any affected product in the possession of consumers.

In selecting the recall level, the principal factors to be considered:
• The methods products are distributed (e.g. Products only for catering purposes); this will require a Trade Recall.
• The extent of distribution (e.g. has the product reached the retail chain); this will require a Consumer Recall.

Who should be notified of the Recall:

Notification has three aspects:
• Notifying statutory authorities;
• Notifying the distribution network/chain and trade customers;
• Notifying the public (in the case of a Consumer level recall).

Mechanics of Notifications:

Authorities who needs to be informed:
• Agri-Food & Veterinary Authority of Singapore

Post Recall Reports

A recall plan must include a recording system for logging food to ensure defected products are returned in order and all food is retrieved.
The effectiveness of the recall plan is based on the number of products retrieved as a proportion to the number of products that left the firm.

Besides assessing the efficiency of the recall plan, an investigation must be carried out to track the reason for the recall. Necessary actions must also be taken to prevent a recurrence of the problem.

Forward Planning

Documentations that will assist in a recall plan:

• A list of telephone contacts for firm personnel, health authorities (include after hours hotline);
• A dedicated toll-free number for consumers to respond to recall notice (include after hours hotline);
• A list of telephone contacts for suppliers, distributors and trade customers (include after hours hotline);
• Blank press advertisements, media releases, news conferences;
• Information on company’s World Wide Websites;
· Incentives such as full refunds, gifts to encourage consumers to return defected goods.
· Video news to complement written news reports/articles.

Determination of Recall Plans:

Class A hazards
These hazards are present in dangerous or defective products that can cause health problems, injuries or death upon consumption. E.g. food containing Botulinal toxins, food with undeclared allergens or labels mix-up on a life saving drug.

Class A hazards require immediate attention. Thus company needs to take comprehensive and constructive corrective actions to notify manufacturers or/and the public. (This depends on the level of recall plan; trade recall or consumer recall.) Actions include repair, replacement, refunds or other measures possible.

Class B hazards
These hazards are present in products that might cause temporary health problems, illness or only pose a slight threat of a serious threat. E.g. drug that is under-strength,
but is not used for life-threatening situations.

Class C hazards
These hazards are present in products that are unlikely to cause any adverse health problems. However, they might violate labeling or manufacturing regulations. E.g. off taste, colour, or leaks in bottled drinks.

Even though product defects are categorized separately, the common point is that these defects are elements of product hazard that require corrective actions to reduce the risk of injury or illness.

References includes:

http://www.foodstandards.gov.au/_srcfiles/FIRP_5Ed_Sept02.pdf
http://www.cpsc.gov/BUSINFO/8002.html#Repreq
http://www.fsis.usda.gov/Fact_Sheets/Focus_On_Freezing/index.asp
http://vm.cfsan.fda.gov/~lrd/recall2.html
http://www.fda.gov/oc/po/firmrecalls/recall_defin.html