Food Investigation Response Manual
6.0 Implementation

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Scope

This section will describe the process of implementing a voluntary recall. Where the recalling firm does not agree to conduct a voluntary recall, other actions will be considered by the Canadian Food Inspection Agency (CFIA) and are described in section 10.

The implementation of a recall to the consumer level requires the preparation of several communication documents, namely the public warning and in some instances a Memorandum to the Minister or Memorandum to the Vice President of Operations. The scope, content, procedure for development and approval, and distribution of these documents is described in section 7.

6.1 Roles and Responsibilities

6.1.1 Office of Food Safety and Recall (OFSR)

In the implementation stage of the recall process, the OFSR is responsible for:

  • The coordination of the information required for a public warning;
  • Preparation and distribution of recall information; and
  • Issuing the recall authorization.

6.1.2 Public Affairs

Please refer to section 7 for more details on their roles and responsibilities.

6.1.3 Canadian Food Inspection Agency Area Operations - General

The Area Executive Director, Regional Director(s), and the Inspection Manager(s), are responsible and accountable for the implementation of the recommended risk management option in their Area and Regions.

The Area Recall Coordinator (ARC) is responsible for coordinating and providing advice and guidance to all area staff on food safety issues and recalls.

The Lead Investigator is the primary contact with the recalling firm that is responsible for implementing the recall in a timely, appropriate, consistent and thorough manner. In some situations, the recalling firm request that their head office coordinate the recall and in that case the Lead Investigator roles may be shared. Where there are multiple recalling firms in more than one province, various Lead Investigators may be assigned from each Area/Region.

6.1.4 Recalling firm

The recalling firm is responsible for the effective implementation of the recall.

6.2 Communication of Decision and Recall Process

References:

Immediately following the decision to request a recall of the affected product(s), the following activities are implemented to ensure timely notification of all partners:

  • The OFSR will inform the ARC (or Lead Investigator) of the decision to request a recall and its classification and depth;
  • The OFSR will complete and distribute the public warning/advisory to various groups for further distribution;
  • The ARC will activate the Area's recall management procedures, which may include informing the Area Executive Director, Regional Directors, Inspection Managers/Supervisors, Operations/Issues Coordinator and Program Networks, Communications Officer, etc. ;
  • The Lead Investigator will contact the responsible firm to request a voluntary recall. A letter confirming these discussions should then be prepared and sent to the recalling firm. This letter should include the recall classification, the regulatory contravention (when applicable), the time frames for action, a summary of the discussion and the Firm's agreement to voluntary recall the product, etc. (refer to Appendix 4A);
  • The ARC will coordinate the recall effectiveness verification strategy with other Regions and ARCs; and
  • The Lead Investigator provides the OFSR with the following information on the affected product(s) as per Appendix 4B (if not already provided):
    • The name and address of the recalling firm;
    • The company spokesperson for the media (if company wishes);
    • Area of distribution of the product;
    • Distribution date;
    • Copies of the product label (enlarged in French and English);
    • Brand name;
    • Common name;
    • Package type, net content, size, weight and/or special marks or features
    • date codes, lot codes, product or UPC codes, GTIN;
    • Expiry / best before / use by (dates); and
    • Any reported complaints, of illnesses or reactions made to the recalling firm.

The Lead Investigator will also:

  • Establish the plan to verify the effectiveness of the recall implemented by the recalling firm and associated responsible firms in consultation with the Inspection Manager/Supervisor and/or the ARC; and
  • Evaluate the recalling firm's strategy to be applied to effectively recall the product.

6.3 Verification of the Firm's Recall Plans and Activities

Reference:

The Lead Investigator will review the firm's recall plan to ensure that all necessary components are included. An on-site visit by an inspector is preferable to conduct a review of the following information but due to the urgency of the recall at this point, the Lead Investigator may find it more expedient to have the information E-mailed or faxed:

  • The notice of recall to the firm's accounts;
  • The news release (if applicable);
  • The distribution list specific for the affected product(s);
  • The firm's plans for conducting effectiveness checks (if applicable); and
  • The firm's plans for correcting or disposing of the affected product.

Note: A checklist to assist the Lead Investigator in gathering all necessary information and to assist in verifying the firm's recall plan can be found in Appendix 4C.

6.3.1 The Notice of recall

6.3.1.1 Purpose

For all classes of recalls, the recalling firm is responsible for promptly notifying each of its affected accounts about the recall. The format, content, and extent of a recall notice should be appropriate with the risk management strategy developed for that recall. In general terms, the purpose of a recall notice is to convey:

  • That the product in question is subject to a recall;
  • That further distribution or use of any remaining product should cease immediately;
  • Reason for the recall (identify the specific area of concern);
  • Where applicable, that the consignee should in turn notify the accounts to whom some or all of the product was further distributed of the recall; and
  • Instructions regarding what to do with the product.

6.3.1.2 Contents

The Lead Investigator will verify that the recall notice is written in accordance with the following criteria:

  • Brief and to the point;
  • Clearly identifies the product, size of the affected lot(s), lot number(s), package and case code(s), and/or UPC codes and any other pertinent descriptive information to enable accurate and immediate identification of the product;
  • Concisely explains the reason for the recall and the hazard involved;
  • Provides specific instructions on what must be done with respect to the recalled products;
  • Provides a ready means for the recipient to contact the recalling firm to confirm receipt of the information, to report how much of the product remains in the consignee's possession, the action taken on the product and how much of the product had been further distributed; and
  • Clearly states that the consignees should, in turn, notify their accounts that a recall is being conducted, where appropriate.

The recall notice should not contain irrelevant qualifications, promotional materials, or any other statement that may detract from the message. Where necessary, follow up communications should be sent to those who fail to respond to the initial recall communication.

6.3.1.3 Transmission

As determined by the recall plan, a recall notice can be communicated by telephone, fax, E-mail or other appropriate measure after consultation with the CFIA. Telephone calls or other personal contacts should be documented in an appropriate manner. The communication of the recall notice should be initiated immediately after the recalling firm has agreed to conduct a recall.

6.3.2 The News Release (Public Warning)

Reference:

Where a public warning is required, the Lead Investigator coordinates the sharing of the recall notice with the recalling firm to verify that the facts are accurate.

In certain situations such as a foodborne illness outbreak, food safety investigations resulting in a recall, the public warning may be a joint release with a municipality, province, the Public Health Agency of Canada (PHAC) or Health Canada.

The scope, content, procedure for development and approval, time standard and distribution of these documents is described in section 7.

6.3.3 Distribution list

The recalling firm must develop and provide to the CFIA, as soon as possible, an accurate consignee list specific for the affected product. This distribution list must include the following information in a clear and legible form:

  • The names of consignees, addresses and telephone numbers. (If a product specific distribution list is not available, the firm should provide a list of its accounts who may have received the products); and
  • A contact person for each consignee (if available).

Additional information such as the quantity of the product and the date shipped to each consignee are also requested; however, more time may be permitted to the recalling firm to submit this information.

The Lead Investigator should also request that the recalling firm provide a separate list of wholesale, distributor or manufacturer type accounts. All distributors should be contacted by the CFIA office in their Area/Regions and requested to also provide their distribution lists.

6.3.4 Affected Product Correction / Destruction

The recalling firm should be advised of the specific requirements of the applicable CFIA legislation and policy. The Lead Investigator must verify that the recalling firm has an appropriate strategy for dealing with the affected product.

The recalling firm's plan to dispose of the affected product is to be verified by the applicable Program Specialist. An OFSR Technical Specialist may assist the Program Specialist as deemed necessary.

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