Food Investigation Response Manual
This section of the manual describes the follow-up stage and the roles and responsibilities of the Canadian Food Inspection Agency (CFIA) and the recalling firm. Follow-up actions described here generally affect product that is not in the marketplace or new production after a recall. Scoping activities are not considered as part of the follow up as scoping activities affects product that is or may be in the marketplace. Scoping is associated with the food safety investigation stage.
Follow-up activities, which include immediate/short term and long term, are key to both the recalling firm and the CFIA. Follow up activities include:
- Verification that the affected product has been controlled by removal from distribution and recovered;
- Verification that the corrective/disposition action for the affected product(s) has been evaluated and appropriate and acceptable, i.e. destruction, disposal, re-label, oversticker, rework;
- Development and implementation of an appropriate risk management strategy where it is determined that the suspect/determined root cause may affect future production;
- Verification that the recalling firm's recall strategy/plan/procedure is revised, as required and reviewed by the CFIA to determine its acceptability;
- Where the recall identifies a new issue involving other manufacturers or need for policy/standard revision; and
- Where trends on food safety concerns or recalls are identified related to an industry sector or country.
9.2 Roles and Responsibilities
9.2.1 Office of Food Safety and Recall (OFSR)
While the OFSR is involved in the food safety investigation and recalls, during the follow-up activities its role shifts. The OFSR is not involved in the follow up activities after the recall; however, the OFSR may be concurrently coordinating the scoping activities to determine if additional affected product is on the market.
9.2.2 Recalling Firm
The recalling firm is responsible to:
- Control recalled product to ensure it does not re-enter the market;
- Verify that all recalled product has been removed from the market;
- Ensure correction or disposition (rework, re-label, export, destruction, etc. ) of the recalled product at the appropriate levels of distribution (consumer, retail, distributor, manufacturer) and which is under the recalling firm's control;
- Evaluate, correct and/or dispose of other products produced under the same conditions, process, packages, ingredients, etc. ;
- Examine difficulties encountered during the recall process which may require special efforts to recover the product;
- Develop, implement, monitor and verify the effectiveness of corrective action taken on current and future production; and
- Conduct a review of the recall strategy and adjust where appropriate.
9.2.3 Lead Investigator
The lead investigator is responsible to:
- Monitor the recalling firm's actions on recovery, reconciliation, control, correction and disposition of recalled product;
- Monitor the corrective action on current and future production of the product by the root source;
- Enter follow up reports into the Issue Management System (IMS) in a timely manner; and
- Provide advice and recommendations to programs where required.
9.2.4 Inspection Manager/Supervisor
- The Inspection Manager/Supervisor is responsible to ensure that the CFIA has conducted the appropriate short term and long term follow-up activities. In some situations consultation with the Area/region Program and Technical Specialists will be necessary.
9.2.5 Other CFIA Branches
The details of the roles and responsibilities of other CFIA Branches, such as Operations Branch, Science Branch or Policy and Programs Branch, are found in the FSIR Framework.
9.3 Follow-Up Activities
Follow-up activities can be broken into the following categories:
- Follow-up to a recall at an establishment (includes repeat offenders)
- Objective: corrective action to prevent reoccurrence
- Lead: Area Operations
- Complimentary Role: advice from Programs and Laboratory support from Science
- Recall identifies a new issue or need for policy/standard/guideline revision
- Objective: Review of policy/standard/guideline to verify risks are effectively and consistently addressed
- Lead: Programs and Policy Branch (with Health Canada as appropriate)
- Complimentary Role: Operations advice on policy/standard/guideline implementation and advice from Science
- Trends associated with food safety concerns and recalls may identify that some form of follow-up activity with an industry sector or country is required
- Objective: Work with sector or foreign country to address trend that goes beyond one company or sector
- Lead: Programs and Policy Branch
- Complimentary Role: Advice from Operations on industry/importer and from Science Branch
9.4 Hot Wash
Dependent on the nature, profile and complexity of a food safety investigation, CFIA management will have the discretion to request a "hot wash".
This informal post food safety investigation process is used to identify which processes worked well and where improvements can be made. It is a critical step to ensuring continual improvement in the Agency's response to food safety incidents.
A more formal Lessons Learned review process may be conducted by the Audit, Evaluation and Risk Oversight (AERO) Branch at the request of senior management.
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