Conducting a Food Product Recall Guide
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This document provides guidance on conducting a food product recall in Australia. It discusses the classification, statistics, objectives, legal requirements, and process for recalls. Recalls are classified by FSANZ and can be for issues like microbial contamination, allergens, or foreign matter. The objectives are to stop distribution, inform parties, and remove unsafe product. A recall is initiated by the responsible food business and involves notifying authorities, retrieving product, and reporting. Guidance is given for various stakeholders' responsibilities in a recall.
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Conducting a Food Product Recall Guide
- 1. RIGHT SOLUTIONS · RIGHT PARTNER 1 RIGHT SOLUTIONS · RIGHT PARTNER Conducting a Food Product Recall Nick Cork MAIFST, ALS Food Consultant
- 2. RIGHT SOLUTIONS · RIGHT PARTNER 2 Contents • Food recall statistics • Food recall protocol • Useful documents • Useful contacts
- 3. RIGHT SOLUTIONS · RIGHT PARTNER 3 Classification of recalls Food recalls are classified by FSANZ under the following categories: • Microbial contamination • Labelling • Foreign matter • Chemical/other contaminants • Undeclared allergen • Biotoxin • Tampering • Other
- 4. RIGHT SOLUTIONS · RIGHT PARTNER 4 Statistics Between 1 January 2005 and 31 December 2014, FSANZ was notified of 586 recalls. The average number of recalls per year for the last 10 years is 59 Source: FSANZ website - http://www.foodstandards.gov.au/industry/foodrecalls/recallstats/pages/default.aspx 12/4/2015
- 5. RIGHT SOLUTIONS · RIGHT PARTNER 5 Statistics Number of recalls by year and recall classification over the last 10 years.
- 6. RIGHT SOLUTIONS · RIGHT PARTNER 6 Statistics Listeria monocytogenes, Salmonella and E. coli are the three microorganisms most commonly associated with microbial food recalls. The ‘other’ classification under microbial contamination includes Clostridium perfringens, Clostridium botulinum, algae, viral contamination and other microorganisms not listed
- 7. RIGHT SOLUTIONS · RIGHT PARTNER 7 Statistics Type of food products recalled from 1 January 2005 to 31 December 2014 due to microbiological contamination
- 8. RIGHT SOLUTIONS · RIGHT PARTNER 8 Statistics Breakdown of food recalls by allergen, as a proportion of all undeclared allergen recalls during the period 1 January 2005 to 31 December 2014
- 9. RIGHT SOLUTIONS · RIGHT PARTNER 9 Statistics Breakdown of undeclared allergen recalls by food type, between 1 January 2005 and 31 December 2014
- 10. RIGHT SOLUTIONS · RIGHT PARTNER 10 Statistics Breakdown of food recalls by foreign matter, as a proportion of all foreign matter recalls, during the period 1 January 2005 to 31 December 2014
- 11. RIGHT SOLUTIONS · RIGHT PARTNER 11 Statistics Types of chemical/ other contamination between 1 January 2005 and 31 December 2014
- 12. RIGHT SOLUTIONS · RIGHT PARTNER 12 Statistics Number of recalls by food category from 1 January 2005 to 31 December 2014
- 13. RIGHT SOLUTIONS · RIGHT PARTNER 13 Objectives The three primary objectives of a food recall are to: 1. stop the distribution and sale of the product as soon as possible 2. inform the government, the food businesses that have received the recalled food and the public (consumer level recalls only) of the problem 3. effectively and efficiently remove unsafe product from the market place
- 14. RIGHT SOLUTIONS · RIGHT PARTNER 14 Legal requirement A food business engaged in the wholesale supply, manufacture or importation of food must – 1. have in place a system to ensure the recall of unsafe food 2. set out this system in a written document and make this document available to an authorised officer on request 3. comply with this system when recalling unsafe food
- 15. RIGHT SOLUTIONS · RIGHT PARTNER 15 Initiation • Food business with primary responsibility for the supply of a food product (sponsor) normally initiates food recall action • Commonwealth Minister has the legislative power to order a food recall when a serious public health and safety risk exists • Recall action may be taken as a result of the food business’s own verification/testing procedures, or from reports the food business receives from a manufacturer, wholesaler, retailer, government or consumer which gives them reason to believe a product they have supplied is unsafe
- 16. RIGHT SOLUTIONS · RIGHT PARTNER 16 The Process • Step 1 – notify FSANZ and the state or territory food enforcement agency where the business head office is located • Step 2 - obtain and consolidate all necessary information about the food product • Step 3 - determine the level of recall required (consumer or trade level recall) • Step 4 - notify trade customers (including any overseas customers) and the public (if a consumer level recall) about the recall
- 17. RIGHT SOLUTIONS · RIGHT PARTNER 17 The Process (cotd) • Step 5 – physically retrieve the unsafe food from the supply chain and remove from sale • Step 6 - dispose of the food product • Step 7 - monitor the effectiveness of the recall • Step 8 - keep appropriate records • Step 9 - report on the recall, including the action taken to prevent a recurrence of the problem
- 18. RIGHT SOLUTIONS · RIGHT PARTNER 18 Distributor Responsibilities • Comply with the directions of the supplier in relation to the recalled food, • Remove the recalled food from the supply chain • Return, destroy or hold the recalled food • Contact businesses they have sold the recalled food to and explain to these businesses what actions need to be taken in relation to the recalled food
- 19. RIGHT SOLUTIONS · RIGHT PARTNER 19 Retailer Responsibilities • Remove all recalled food product from sale and (if the food is not for immediate destruction or disposal) ensure it is held, separated and identified from other food • comply with the directions of the supplier, distributor or the sponsor of a recalled food product • accept returns of the recalled product from consumers and issue refunds
- 20. RIGHT SOLUTIONS · RIGHT PARTNER 20 State Responsibilities • Provide technical advice to the sponsor to help with assessing the food safety issue identified • Provide advice on whether a food product should be recalled • Advise the sponsor on recall actions and requirements • This may include how the recalled food product is to be collected and disposed of and corrective actions needed • Liaise with the FSANZ recall coordinator about food recalls occurring in their state or territory • Monitor the effectiveness of food recalls in their state or territory and if any issues with the recall are identified, notify the recall sponsor
- 21. RIGHT SOLUTIONS · RIGHT PARTNER 21 Local Government Responsibilities • Check that local food businesses have removed recalled food from sale • Monitor the disposal of recalled food, including: – oversee the destruction of food – issue a statement certifying that the food product has been destroyed • Report back to the state or territory government, as required
- 22. RIGHT SOLUTIONS · RIGHT PARTNER 22 FSANZ Recall Coordinator Responsibilities • Liaise with the sponsor about the food recall • Classify the recall according to the reason the food is being recalled • Help the sponsor draft a method of communicating the food recall to the public (e.g. press advertisement) • Liaise with the home state and other state or territory action officers about the food recall • Disseminate the official food recall notification to state and territory governments, Commonwealth government, the New Zealand Ministry for Primary Industries and industry contacts – this notification includes information about the food product being recalled including package description and image, date marking details, distribution and disposal details
- 23. RIGHT SOLUTIONS · RIGHT PARTNER 23 FSANZ Recall Coordinator Responsibilities (cotd) • Notify international government organisations • Notify the International Food Safety Authorities Network (INFOSAN), if the food product has been imported or exported • Notify the allergen information group, if the recall is due to an undeclared allergen • Notify OzFoodNet, which in turn notifies epidemiologists in all state and territory health departments for appropriate follow up action if there are human cases of illness • Alert subscribers of FSANZ food recall alerts • Ensure the food recall information is published on the FSANZ consumer recalls webpage as well as on the FSANZ Facebook and Twitter accounts, if it is a consumer recall • Provide the ACCC with the sponsor’s post recall report which includes details on the effectiveness of the food recall and proposed corrective action
- 24. RIGHT SOLUTIONS · RIGHT PARTNER 24 Process Summary
- 25. RIGHT SOLUTIONS · RIGHT PARTNER 25 Reasons for a Recall • Presence of pathogenic bacteria (e.g. Salmonella) • Chemical contamination (e.g. chemical sanitiser) • Foreign matter contamination (e.g. pieces of glass, metal or plastic) • Labelling errors (e.g. incorrect/insufficient cooking instructions) • Undeclared allergens (e.g. allergens such as peanut, milk or soy products not being declared on the label) • Packaging defects (e.g. where the integrity of the package is compromised and a piece of the packaging results in a choking hazard) • Under-processing resulting in potentially unsafe food
- 26. RIGHT SOLUTIONS · RIGHT PARTNER 26 Recall or Withdrawal? A food product may be withdrawn from sale because: • The food product has a quality defect (e.g. colour or texture) • It is underweight • It does not comply with the Code (provided the breach does not pose a food safety risk) • As a precaution, pending further investigation of a potential food safety risk
- 27. RIGHT SOLUTIONS · RIGHT PARTNER 27 Recall or Withdraw – decision matrix
- 28. RIGHT SOLUTIONS · RIGHT PARTNER 28 Level of Recall 2 levels of recall – Trade and Consumer, determined by the following factors: • Channels by which the food product has been distributed (e.g. food product destined only for catering purposes would usually result in a trade level recall only) • Extent of distribution (e.g. if the food product has reached the retail chain and consumers, this would usually result in a consumer level recall) • A trade level recall is conducted when the food has not been available for direct purchase by the public, such as food sold to wholesalers and caterers • A consumer level recall is conducted when the food has been available for retail sale • Level of recall should be determined in consultation with the home state
- 29. RIGHT SOLUTIONS · RIGHT PARTNER 29 Scope of Recall Where a food safety issue has been identified, sponsors should also consider the possibility of the same problem occurring in: • Different package sizes of the same line • Different flavours or varieties of the product • Food products with a different batch number or date marking • A different food product processed on the same line or in the same plant • The same or similar food products packaged under a generic label
- 30. RIGHT SOLUTIONS · RIGHT PARTNER 30 Notification Requirements Food businesses need to contact government as soon as they consider a food recall is, or may be, needed. Relevant government officers to be notified include: • The home state—by phone (food enforcement agency in the state/territory where the food business’s head office is located) • FSANZ—by phone • ACCC—FSANZ will notify the ACCC but the sponsor may do this on their own behalf
- 31. RIGHT SOLUTIONS · RIGHT PARTNER 31 Information Requirements The sponsor should be able to provide the following information to FSANZ, in order to facilitate an effective food recall: • Company contact details • Product manufacturer’s details • Product details including: name (as it appears on the product packaging), date marking, package size and description, and any other identifying markings available including: Lot/APN/EAN code • An image of the product or product label • Nature of the problem, the results of any testing undertaken and what corrective action will be taken • Quantity of the batch manufactured and the date and amount released
- 32. RIGHT SOLUTIONS · RIGHT PARTNER 32 Information Requirements (cotd) • Quantity of the recalled food product that can be accounted for • Distribution in Australia—where possible and practical, include a distribution list in English, with contact details of who you sold the recalled food to—at a minimum, state the types of premises at which the food product is being sold • Any import/export information (if applicable) including overseas distribution and/or importer details
- 33. RIGHT SOLUTIONS · RIGHT PARTNER 33 Notifying Customers • The sponsor is responsible for advising all direct customers that the food is being recalled • Notifications need to include a clear statement about the reasons for the recall, plus details allowing easy identification of the food and information about how it will be recovered and/or disposed of. • The sponsor should confirm with its customers that the notification has been received, for example, by requesting confirmation of having received an email. • The sponsor must keep records to demonstrate that all of its direct customers have been notified of the food being recalled, in order to satisfy the post recall reporting requirements
- 34. RIGHT SOLUTIONS · RIGHT PARTNER 34 Notifying the Public A written recall notice needs to contain the following information: • Product description • Where the product has been sold • The problem • Food safety hazard • What to do • Contact details
- 35. RIGHT SOLUTIONS · RIGHT PARTNER 35 Guidelines for Food Recall Advertisements Food recall press advertisements should: • Be headed ‘Food Recall’ in red bolded text • Be a minimum of 3 columns wide and 12 centimetres high • Be enclosed in a red diagonally hatched border, with the internationally recognised red safety triangle in the top left-hand corner • Use appropriate font size and style to ensure the printed text is easy to read • Include the words ‘See www.foodstandards.gov.au/recalls for Australian food recall information’ at the base of the advertisement
- 36. RIGHT SOLUTIONS · RIGHT PARTNER 36 Other avenues • Media release – faster, based on press advertisement copy • Radio announcement – in conjunction with press and media release statements • POS material – enlarged copy of press release • Online/social media announcements • Direct consumer contact, if details held
- 37. RIGHT SOLUTIONS · RIGHT PARTNER 37 Retrieval and disposal of product • Returns to retailers • Returns via distributors • Direct customer returns • Must be labelled, separated and disposed of in accordance with Clause 11 of Standard 3.2.2 – Food Safety Practices and General Requirements of the Code
- 38. RIGHT SOLUTIONS · RIGHT PARTNER 38 Post Recall Reporting Requirements • Interim report – within 2 weeks of recall • Final report – within one month of recall • The company’s Food Recall Plan should document who is responsible for producing these reports
- 39. RIGHT SOLUTIONS · RIGHT PARTNER 39 Useful documents and tools • GS1 RecallNet – online standardized industry owned tool to notify FSANZ: https://recallnet.gs1au.org/ • Online templates for press advertisements: http://www.foodstandards.gov.au/industr y/foodrecalls/recalltemplates/Pages/defau lt.aspx
- 40. RIGHT SOLUTIONS · RIGHT PARTNER 40 Who to contact
- 41. RIGHT SOLUTIONS · RIGHT PARTNER 41 Further Support Nick Cork MAIFST ALS Food and Pharmaceutical Nick.cork@alsglobal.com T – 02 8832 7535 M – 0476 830 459
Editor's Notes
- Meats and dairy are recalled due to Listeria monocytogenes contamination more frequently than other foods due to the importance the food industry and government place on ensuring this pathogen is not present in ready-to-eat foods and the extensive testing of food products for this bacterium. The Food Standards Code specifies limits for Listeria monocytogenes in certain foods in Standard 1.6.1 – Microbiological Limits for Food, including cooked and/or cured meats. Foods that pose the most risk for Listeria infection are ready-to-eat foods that support the growth of Listeria monocytogenes such as meat and dairy products and are stored at refrigeration temperatures for long periods, thereby enabling Listeria to grow. A wide range of foods are recalled due to Salmonella spp contamination, represented above by the ‘other’ category. Foods captured by this category include eggs, dairy, seafood and confectionery. ‘Fruits, vegetables and herbs’ recalled due to Salmonella were mainly sprouts, fresh parsley and dried herbs. The ‘other’ category for Salmonella includes sauces such as Tahini. Limits for Salmonella in certain foods are specified in Standard 1.6.1. Dairy products are more commonly recalled due to concerns with process hygiene, indicated through E. coli testing, than other categories of food. Other products commonly recalled for E. coli include fresh sprouts, salads and some processed meat products. More information on the microbiological limits, Standard 1.6.1 - Microbiological Limits for Food can be found on the Food Standards Code page.
- The chart shows that undeclared allergens are the second most common reason for food recalls in Australia with 172 recalls between 1 January 2005 and 31 December 2014 and an average of 17 recalls per year in this category. A spike in undeclared allergen recalls followed the introduction of new labelling laws in 2002 (as seen in Figure 2 under the 2004 year column). During the last 10 years, undeclared peanuts have been the most common allergen related recall, accounting for 21% of all allergen related recalls. Dairy and wheat were the second (17%) and third (16%) most common types of allergen recalls respectively
- This chart shows that during the last 10 years, the most common food type to be recalled due to undeclared allergens is processed food, accounting for 33% of all undeclared allergen recalls. Confectionery and baked goods were the second (18%) and third (15%) most common types of food recalled due to undeclared allergens. Other food types typically involved in undeclared allergen recalls include: cereals, seafood, meat and poultry, nuts and spices
- This chart shows that between 2005 and 2014, there were 126 recalls due to foreign matter. The most common types of foreign matter found in food were plastic (34%), metal (32%) and glass (22%).
- Recalls due to chemical contamination or other contaminants occur less frequently, with the numbers of recalls over the past 10 years ranging between zero and 11 per year. The total number of recalls due to chemical/ other contaminants between 1 January 2005 and 31 December 2014 was 36 recalls. The chart here indicates the contaminants present in food recalled under this category. 25% of foods recalled under this category are categorised under ‘other contaminant’. This includes naturally occurring iodine. Pharmaceutical ingredients not permitted in food accounted for 17% of recalls under this category and included things such as prescription medication (e.g. sibutramine in food marketed as weight loss products).
- This chart gives an indication of the types of foods most commonly associated with food recalls. The food categories listed here have been developed by FSANZ to aid reporting requirements and data collection. The food type most commonly associated with a recall is ‘Mixed/Processed Food’. This is most likely due to the wide range of foods that are categorised under this heading, including most long-life packaged food and manufactured items that contain multiple ingredients. ‘Meat and meat products’ is the second largest food type associated with recalls. It includes a wide variety of meat products, mainly processed and, ready-to-eat sliced meats from the delicatessen, such as ham and salami.
- The Australia New Zealand Food Standards Code (the Code) requires manufacturers, wholesalers and importers of food to have a system in place to manage the recall of unsafe food. The requirement is specified in clause 12 of Standard 3.2.2 – Food Safety Practices and General Requirements. It states that:
- One of FSANZ’s functions is responsibility for coordinating recall action, at the request of the Australian states and territories. This means that when FSANZ is notified of a food recall, it liaises with the food business and state and territory government to gather and collate all necessary information. This information is then disseminated to state and territory governments, other government bodies and the food industry.
- All states and territories have legislative powers to require that a food product be recalled where necessary to: 1. prevent or reduce the possibility of a serious danger to public health; or 2. mitigate the adverse consequences of a serious danger to public health. This is called a mandatory recall. However, mandatory recalls are rare with almost all recalls being initiated by the sponsor. State and territory action officers are government officers responsible for providing advice on recalls and coordinating monitoring and enforcement activities in relation to recalls within their own state or territory
- The FSANZ recall coordinator will complete a recall report with the sponsor in order to gather all necessary information on the food product to be recalled, including why the food is being recalled and action to be undertaken
- Food safety issue and not a food quality issue – food quality issues are dealt with by a withdrawal of the product from sale, rather than a full recall.
- If a risk to food safety is then confirmed, the food product must be recalled
- If the food safety issue is present in other foods, batches, sizes or brands, all of these foods will need to be recalled. The sponsor must also consider whether there are other products on the market or in the food supply chain that may have been affected by the same hazard as the food subjected to the recall. This is referred to as trace-back. For example, if the problem is found to be linked to one or more raw materials supplied to the sponsor, then the sponsor needs to notify the supplier of the raw materials to enable this supplier to notify other customers of the raw materials. This may then result in additional recalls being initiated for more food products by other food businesses
- Food businesses who are able to notify all customers who have purchased the food being recalled, for example, by accessing customer records through membership or loyalty programs, must still notify FSANZ and the home state of the recall. Notifying customers is only one requirement of a recall. Government needs to be notified to confirm that all customers have been informed, the affected food has been removed from the supply chain, appropriate correction action has been taken and the food has been disposed of in accordance with food legislation
- The above information is normally provided to FSANZ through a phone interview and forms the basis of an initial recall report. A copy of a blank recall report is available from the FSANZ website at www.foodstandards.gov.au/recalltemplates. If your business is conducting the recall through the GS1 Recallnet portal, the above information will be sent to FSANZ electronically
- including distributors, wholesalers, overseas importers and retailers. It is important that distributors and sub-distributors also provide the recall notification to their direct customers so that each business in the supply chain that has received the recalled food is notified. Notification should be made urgently by telephone and followed up in writing via emails, fax or through the use of rapid electronic systems such as GS1 Recallnet
- Public notification of the food recall is essential for consumer level food recalls, as the food poses a food safety risk to the public. There are numerous ways that the public can be informed of a recall and these are discussed below. In most circumstances, using multiple methods to inform the public will be the most effective. The methods chosen will depend on: ¡¡ the urgency of the food safety issue, e.g. if the food presents a high safety risk to consumers a media release and/or radio advertising may be needed, as it can take several days to place a newspaper advertisement ¡¡ how widely the product has been distributed i.e. locally or nationally ¡¡ the customer base of the food being recalled, e.g. if the recalled food is sold to particular groups (e.g. specific nationalities/cultural groups), the public notification should be targeted to these groups. Having regard to the options discussed below, and in consultation with your home state, you should consider the most effective method(s) to inform consumers that may have purchased the recalled product. FSANZ supports notifying the public of consumer level recalls through notices placed on the FSANZ website at www.foodstandards.gov.au, via email through the food recall alert subscription service and through social media networks such as Facebook and Twitter
- It is important that, wherever possible, food recall advertisements appear in the front pages of the chosen daily print media. If this is not possible they should appear in the first half of the newspaper (early general news). The classifieds section is not a suitable location for recall advertisements. Advertisements may also be placed in online versions of newspapers. The recall notice must not include the words ‘voluntary recall’. While this term was previously used to indicate that a food business had voluntarily undertaken the recall, it created confusion for retailers and consumers, with some interpreting it to mean that it was voluntary for them to take action in relation to the recalled food
- (1) A food business must ensure that food for disposal is held and kept separate until it is: (a) destroyed or otherwise used or disposed of so that it cannot be used for human consumption; (b) returned to its supplier; (c) further processed in a way that ensures its safety and suitability; or (d) ascertained to be safe and suitable. (2) In subclause (1), ‘food for disposal’ means food that: (a) is subject to recall; (b) has been returned; (c) is not safe or suitable; or (d) is reasonably suspected of not being safe or suitable. (3) A food business must clearly identify any food that is held and kept separate in accordance with subclause (1) as returned food, recalled food, or food that is or may not be safe or suitable, as the case may be. (4) A food business must not sell food that has been already served to a person to another person unless the food was completely wrapped when served and has remained completely wrapped.