Food Safety controlIntroduction
This is to provide a guidance for carrying out food recalls. It explains what should be done when food products have to be removed from supply or use by consumers for public health and safety reasons. Recall of food product is in the common interest of the industry, the government and in particular, the consumer.
What is a recall?
A recall is defined as an action to remove from sale, distribution and consumption, foods which may pose a safety hazard to consumers.Role of the recall
The recall procedure at its various stages including follow-up checks to ensure that recalls are successful and that subsequent batches of the food products are safe for human consumption. A recall should be undertaken in consultation with the Food and Environmental Hygiene Department and preferably with prior agreement on the recall strategy. During the recall process, company personnel should keep all relevant parties informed of the latest developments.Initiation of a Recall
A recall may be initiated as a result of reports/complaints referred to the company from a variety of sources. The reports may be referred by manufacturers, wholesalers, retailers, medical practitioners, government agencies and consumers. A recall of goods manufactured overseas may also be initiated by reports appearing in overseas bulletins and similar publications of health authorities, or from information received directly from such authorities.
To minimize the risk that may arise, recalls are usually carried out in the shortest time practicable. Companies are encouraged to develop its own recall procedure so that it can respond promptly to any emerging situation. The procedure should be able to achieve the purposes of stopping distribution and sale of an affected item, notifying the public and the Food and Environmental Hygiene Department of the problem, and effectively and efficiently retrieve from the market any product which is potentially unsafe.Informing the Consumer
Depending on the extent of the recall, the company concerned should inform the consumer of the recall at the earliest possible moment. Information dissemination may take the form of a press release
, letter to the concerned parties
or paid advertisement in the media
. Sufficient telephone hotline service should be made available to deal with enquiries.Assessment of the Recall
Depending on the imminent risk that may be involved, there are two classes of recall:
(a) Class one recall-emergency situation.
This arises when there is a reasonable probability that the use or consumption of the product would cause adverse health consequences or death.
(b) Class two recall-concern situation.
The product may have serious defects which represent a potential health risk.
To expedite the classification, the company should provide all information on the 'Food Recall Notification Form'. Other relevant details may include:
(a) availability for investigation of suspect sample or other samples;
(b) assessment of risk; and
(c) proposed recall classification.
Since some of the above information may be of a commercially sensitive or private nature, the Department will, upon request by the company concerned, maintain confidentiality on selected information as and when necessary.
In determining the recall level, the principal factors to be considered are the significance of the risk, the channels by which the goods have been distributed and the level to which distribution has taken place.Product Recovery
Products may be recovered by return to supermarkets
, return via distribution chains
or direct return from consumers
. The product is to be recovered to a central site, or in the case of widely distributed product, to major recovery sites. The recovered product must be stored in an area which is separated from any other food product. Accurate records are to be kept of the amount of recovered product and the batch codes of the product recovered. After recovery, products may be corrected or reprocessed before release to the market if it is fit for human consumption. Otherwise the product is to be destroyed.Follow-up Action
Post-recall should provide the Department with an interim report as soon as a recall is completed, in any case not later than one month after the announcement of a recall. A final report should be ready within two months of the recall. The reports should contain essential information such as:
(a)the circumstances leading to the recall;
(b)the action taken by the company including details of any publicity;
(c)the extent of distribution of the relevant batch locally and in overseas;
(d)the result of the recall (quantity of stock returned, corrected, outstanding, etc.);
(e)the proposed method of disposal or otherwise of recalled stock with record of destruction;
(f)the action proposed to be implemented in future to prevent a recurrence of the problem.
The report helps to establish the effectiveness of the recall. Unless satisfactory reports are received, the Department may consider taking further action, e.g. stepped-up inspection, against the company concerned.
Effectiveness of Recall Action
To be effective, recall notification must reach as far as the product has been distributed. The effectiveness of the recall is assessed upon the amount of product returned as a percentage of the amount of product which left the manufacturer while taking into account the retail turnover of that product.Conclusion
Worldwide, cooperation between the company and the regulatory authority has proven over the years to be the quickest and most reliable method to remove potentially dangerous products from the market. These guidelines outline the procedures which would enhance efficiency and transparency in the recall of food products. The implementation of such guidelines will hopefully minimize the loss inflicted on the company and the community at large.
p.s. however this is only for Hong Kong. Whether Singapore follows the same practice is not known yet=(