Good Importing Practices for Food
8.0 Complaint Handling and Recalls

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8.1 Product Complaints

8.1.1 Product Complaints

The importer has an effective system for handling and investigating complaints.

Rationale

Product complaints are an important indicator of possible deficiencies in manufacturing controls and/or deficiencies in the distribution handling system. When the complaint handling system itself is deficient, it could result in failure to identify and eliminate risks.

Assessment Criteria

  • The importer has a system in place to handle and investigate product complaints as follows:
    • the importer has identified the person or persons responsible for receiving, evaluating, categorizing and/or investigating complaints;
    • complaints are accurately categorized according to safety, composition, quality and other regulatory concerns;
    • potentially serious complaints are forwarded immediately to appropriate personnel for action;
    • safety and contamination complaints are investigated by appropriately trained technical personnel;
    • examination of the complainant's specimen, the retail product or other product of the same code is conducted on complaints related to food safety;
    • complaints pertaining to composition, quality, fraud and other regulatory concerns are investigated in an effective manner;
    • the depth of the investigation is appropriate to the risk and similar complaint trends;
    • appropriate corrective action is taken for deviations identified during the investigation.

See Section 7.6.1, Complaint Records

8.2 Recall System

8.2.1 Recall Procedure

Every importer of a food establishes a written procedure to permit the complete, rapid recall of any lot of food from the market.

Assessment Criteria

  • The written procedure identifies the person or persons responsible (e.g., recall coordinators) and the roles and responsibilities of those who coordinate and implement a recall.
  • The procedure specifies methods to identify, locate and control recalled product, and includes a requirement to investigate other products that may be affected by the hazard, and should be included in the recall.
  • The procedure requires that the recall be monitored to assess its effectiveness (e.g., an "effectiveness check" is conducted to the appropriate level of distribution specified in the recall notice).
  • Records on the recall and on the effectiveness check are available.
  • The Canadian Food Inspection Agency is immediately notified in the region where the importer is located. This notification includes the following:
    • the amount of product produced, the amount in inventory and the amount distributed;
    • the name, size, code or lot numbers of the food recalled;
    • the area in which the product was distributed (e.g., local, national, international);
    • the reason for the recall.

8.2.2 Recall Capability

Recall procedures are tested periodically to verify the capability to rapidly identify and remove product from the market.

Assessment Criteria

  • The importer demonstrates the capability to provide accurate information on a timely basis, to verify the company's capability to rapidly identify all affected product and remove it from the marketplace. For example, the importer conducts periodic testing (e.g., internal simulations) to verify capabilities to control a code lot and to reconcile the amount of product produced imported, in inventory and in distribution. (Note: Importers should also be able to verify that their procedure will identify other lots that might have been affected.) Any deficiencies in the recall procedure are identified and corrected.
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