This flow chart outlines the stages of the food safety investigation and recall process
The first stage is the trigger. The trigger is any specific source of information such as a company initiated recall, a consumer or trade complaint, an audit or inspection finding, an analytical result, epidemiology, information from other government departments, etc. The trigger prompts the initiation of a food safety investigation when the issue is within the scope of legislation that is administered or enforced by the CFIA.
The second stage is the food safety investigation where a health and safety concern and/or a contravention of legislation enforced by the CFIA is suspected. This can occur at different levels in the supply chain such as the consumer, the retailer, the distributer, the manufacturer or the importer. The following outlines the steps taken during a Food Safety Investigation: confirm hazard; investigate suspect root cause; identify affected products to confirm whether a possible health risk or regulatory violation exists; scoping; and determine if additional affected products are in the market place. If a possible health risk or violation is determined, based on legislation administered or enforced by the CFIA, then the investigation proceeds to the next stage (decision making) for the food safety issue. If there is no health risk or violation, then no further regulatory action is needed.
The third stage is decision making. It is first determined whether the situation represents a food safety issue, with or without a Health Risk Assessment. Health risk issues can be physical, chemical, biological or allergen. The Office of Food Safety and Recall coordinates the development and consideration of risk management options and strategies as well as assigns the recall a class I, II, III or provides a referral for other risk management options. If the issue does not represent a health risk (non-health risk issues could include deceptive practices, misrepresentation, quality, spoilage, wholesomeness and labelling), the Office of Food Safety and Recall coordinates the development and consideration of risk management options and strategies as well as assigns the recall a class III or a referral.
The fourth stage is the implementation of the recall. When it is determined that the appropriate risk management strategy is to recall the affected product, the recalling firm is advised and CFIA staff work with the recalling firm to implement the recall. The recalling firm is responsible for preparing the recall plan, initiating the recall, preparing distribution lists, warning the public, notifying and reconciling accounts, collecting and controlling the recalled product, controlling returns, assessing the safety of current and future production as well as conducting an internal review, as appropriate. The CFIA will warn the public, report in the Issues Management System, obtain a copy of the product label, describe the product, determine the area and level of distribution, request distribution lists, review the firm's recall plan and notice to accounts, send a confirmation letter to the firm and detaining the product, if required. Where it is determined that the appropriate risk management strategy does not involve a recall, some possible follow-up activities include inspection, sampling, sending a letter of non-compliance, scheduling a meeting, creating a public advisory, seizure or detention of the affected product and prosecution.
The fifth stage is the verification of recall effectiveness to ensure that the recalling firm has effectively removed the affected product from the market. The firm is responsible for controlling the affected product and its return, and monitoring and assessing the effectiveness of the recall. The CFIA will verify the clarity of the firm's recall notice, create a statistical plan to select account samples, review the firm's data on recall effectiveness, ensure the accounts were notified of the recall, remove product from sale, control the affected product, ensure that verification was conducted on product further distributed or used for manufacturing as well as decide the overall effectiveness of the recall.
The sixth and final stage is the follow-up. The CFIA conducts follow-up activities with the recalling firm during and following the recall to ensure that issues are handled consistently and appropriately. The recalling firm is responsible for disposing of recalled product, controlling warehouse stock, implementing corrective actions, monitoring future production, conducting an internal review as well as analyzing trends. The CFIA will monitor the firm's actions on returns and warehouse stock, supervise the disposition of recalled product, enforce corrective action on current and future production, analyze trends as well as develop and revise codes and standards.