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Recall procedure: A guide for food businesses

Introduction

The Canadian Food Inspection Agency (CFIA) created this guidance to help you prepare a recall procedure to carry out effective recalls. It may also be used to assist you with complying with the requirements of the Safe Food for Canadians Regulations (SFCR) regarding recall procedures (subsection 84(1) and section 85 of the SFCR).

What is a food recall?

The term "recall" is not specifically defined in the Safe Food for Canadians Act nor in the Safe Food for Canadians Regulations. In general terms, "recall" refers to the removal of a food from further sale or use, or the correction of its label, at any point in the supply chain as a risk mitigation action.

It's your choice

Other guidance developed by provincial governments, industry associations, international organizations or academic bodies may also be used as long as the recall procedure that is developed will achieve the outcome of an effective food recall. Always ensure that the guidance you choose is relevant for your particular business, product and market requirements.

What is included

This guidance provides a step-by-step approach that you may wish to consider for your recall procedure to implement a recall quickly and effectively.

Roles and responsibilities

You are responsible for complying with the law and ensuring that food for which you are responsible for is safe for human consumption. You may demonstrate compliance by ensuring that the food, the establishment in which the food is prepared and any activities conducted in relation to the food (among other areas you may be responsible for) meet relevant legislative requirements including food safety and, where applicable, those pertaining to food recalls.

During a food recall, the CFIA's role is, generally, to:

1.0 Step-by-step recall procedure

The following twelve steps are best practices that could be incorporated into your recall procedure.

Step 1: Assemble your recall management team

Identify persons in your business who would be involved in implementing a recall and assign duties to each person. This will allow you to action your recall procedure in an effective manner. The number of members in your recall management team will vary according to the size and structure of your business.

In your recall team, you should consider including people who are responsible for:

Consider having the following details for each member, including after-hours contact details as recalls may be needed at any time:

Responsibilities Name and position Business phone number After hours phone number Alternate person name and position
The duties assigned to the person Name of the person and their position title xxx-xxx-xxxx xxx-xxx-xxxx Name of the alternate and their position title

At the start of a recall, the person who is responsible for conducting recalls within your business should assemble the recall management team, or any other person assigned to help with the implementation of the recall, and ensure that:

Tip

Review and update the membership of your recall team and their details on a regular basis.

Step 2: Notify the CFIA

Immediately notify the CFIA recall coordinator who covers the area where your business is located if the CFIA is not already aware of the incident.

To allow the CFIA to assist you in your investigation, and to take any further action, if needed, to protect the public and mitigate any potential risk of injury to human health, the recall coordinator may ask you to provide the following:

If the food is already being recalled when you notify the CFIA, the recall coordinator may ask for the following:

Step 3: Identify all food to be recalled

In addition to the food directly affected, determine if:

If this is the case, include this food in your recall.

Tips

Step 4: Hold and segregate food included in the recall that is still in your control

Ensure that all the food affected by the recall that is still in your control is not distributed by:

Step 5: Review the CFIA public food recall warning (when applicable)

The CFIA will inform you if a public warning to inform consumers is required when you conduct a voluntary recall. The CFIA prepares the public warning using a standard template and asks you to review it to ensure the accuracy of your food business' name, the description of the recalled food and its distribution. If you wish, the CFIA can add your contact information for consumers and/or the media. Once finalized, the CFIA sends English and French versions of the public warning for dissemination to the media and posts it on the CFIA's and the Government of Canada's Health risk and safety websites.

Step 6: Prepare the distribution list

As the business conducting the recall, create a food and lot code specific distribution list, that identifies:

The CFIA will ask to receive the list as soon as possible after the initiation of the recall.

Tip

Ensure you have a complete list of clients by adding together the amount of affected food for each client on your distribution list to the quantity of affected food that is still under your control. If this sum is less than the total quantity of the food to be recalled, you may need to review your list of clients and/or verify the inventory of affected food in your control.

Step 7: Prepare and send the notice of recall

As the business conducting the recall, immediately notify all of your clients who received or may have received the recalled food. Consider:

If it is not possible for you to notify all clients simultaneously, prioritize the notification and contact distributors and clients who serve vulnerable populations (for example, hospitals, care homes, and daycares) first.

Note

You may consider using the notice of recall to obtain additional information from your clients, such as:

  • how much of the recalled food remains in their possession
  • how much of the recalled food has been further distributed

Step 8: Verify and document the effectiveness of the recall

To ensure an effective recall, verify that the clients to whom you shipped the recalled food:

Document the results of your verification as follows:

Tip

Contact the clients who have not confirmed receipt of the notice of recall.

Be aware

The CFIA may follow-up with some of your clients to verify the effectiveness of the recall. If the CFIA determines that your recall was ineffective, the CFIA may ask you to repeat the recall.

Step 9: Control the recalled food

To prevent the recalled food from re-entering the marketplace:

Step 10: Decide what to do with the recalled food

Decide what disposition action you will take on the recalled food (for example, correction, re-export, destruction) and inform the CFIA of your decision. The CFIA will review your method of disposition and may request to witness the disposition prior to its implementation.

In addition:

Step 11: Choose a corrective and preventive measure

Identify the cause of the incident that led to the unsafe food. Ensure appropriate corrective actions are in place and that preventive measures are implemented to prevent similar recalls in the future.

Document the measures taken in your food recall documentation.

Note

Be prepared to demonstrate the effectiveness of your corrective and preventive measures to the CFIA.

Step 12: Conduct a post recall review

After conducting a recall, meet with your recall management team or with those who helped with the implementation of the recall and discuss how the recall went. Document the following in your food recall documentation:

2.0 Tell me more. Further reading

If you are subject to the Safe Food for Canadians Act and its Regulations, the following documents prepared by the CFIA contain information that help explain food safety controls, demonstrate how to develop them and provide examples:

Annex A
Notice of recall template

Urgent – Recall of (enter food name)

(enter date)

(enter name and address of your business)

Dear Customer or Attention (enter name of customer contact),

(enter your business name) is recalling the food listed below because (state the reason for the recall, for example, presence of an allergen not declared on the label, bacteria [name], foreign pieces of material, etc.).

Brand Product Size UPC Codes

Please discontinue the distribution, sale or use of the food immediately. Remove the food from stock or display, count the quantity still under your control and ensure that the food will no longer be distributed, sold or used. Please do this by [insert one of the following two sentences]

[1] storing all recalled product in a secure, segregated place and mark as "recalled"

[Include a paragraph providing information, as appropriate, regarding your business' policy on crediting for recalled food, identification of recalled food with the mark "recalled" and arrangement for the pick-up recalled food. Example: We will credit you for the recalled food. Please mark the food "recalled" and our staff will call you to arrange pick up.]

[2] proceeding with the destruction of all recalled food in such a manner that they cannot be sold or used

[Include a paragraph providing information, as appropriate regarding your business' policy on crediting for recalled food]

If you further distribute this food, please immediately contact all your clients to whom you distributed this food and inform them of this recall and actions they should take on the food.

If any of the recalled food is repackaged, relabelled or reworked by your business, your final product may also pose a health risk. Please contact your local CFIA office immediately should this situation apply.

Important:

Please acknowledge receipt by signing and sending this document (via fax or e-mail) to (enter your business' contact name) at (enter your business' fax number or e-mail address).

Date / Time Received: space

Name (please print): space

Business name: space

Signature: space

Thank you for your cooperation.

[Sign here]

(enter your business' contact, their position and your company name)

Date modified: