Chapter: Operations and Documentation
Section: F.B.19 Recall
Sub-Section: N/A

Elements

The regulatory requirements contained in this guideline will be met when:

F.B.19 (01) A written recall plan containing all necessary elements is developed and implemented, and the plan is periodically evaluated for effectiveness and amended as necessary. (Risk Ranking: High)

Rationale

When a product presents a health risk to consumers, it is critical that it be removed from the marketplace quickly. Safety issues with food products may be due to chemical, physical or biological contamination of the products or the presence of undeclared allergens due to mislabelling.

The operator of a fish processing operation must develop, implement and periodically evaluate a written recall plan to ensure the timely and effective recall of fish products when necessary. A recall plan that permits fast and effective recall of any product shipped or distributed by the operation is critical to food safety. A food recall aims to:

  • remove all affected product from sale or use; and
  • inform the appropriate regulatory agencies, such as the Canadian Food Inspection Agency (CFIA).

Recall Plan

A written recall plan should include:

  • the name(s) of all personnel responsible for the coordination and implementation of a recall, their contact information, and a description of their roles,
  • procedures to identify, locate and control recalled products,
  • procedures to investigate the potential for other products to be affected and locate and control them,
  • methods to investigate and respond to consumer complaints,
  • traceability procedures to track the movement of products and ingredients one step back and one step forward,
  • procedures to identify and locate all related records and product documentation,
  • procedures to notify relevant government authorities such as the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) and the Canadian Food Inspection Agency (CFIA),
  • procedures to periodically evaluate the effectiveness of the recall plan.

The effectiveness of a recall plan can be evaluated by conducting a mock recall exercise. A mock recall can help to identify any gaps or weaknesses in the plan.

A mock recall includes:

  • choosing a recall scenario that describes a food safety problem with a specific lot of finished products,
  • following the recall procedures; identifying and locating all of the affected product.
    • Government authorities and customers are not required to be notified during a mock recall exercise; however, they may be happy to work with clients to help test their recall plans as recalls also affect them.

If the mock recall does not provide for timely and effective identification of all recalled products, operators are required to amend the recall plan and re-evaluate the effectiveness of the amended plan.

In the event that a hazard exists that may warrant a recall, OMAFRA will notify the CFIA. The CFIA receives all relevant information, conducts a risk assessment, and determines the level of recall (if any). OMAFRA may assist throughout the process, but the CFIA is responsible for leading all matters related to the recall.

Regulatory References

  • Food Safety and Quality Act, 2001; O. Reg. 465/19 s. 45
      1. The operator of a fish processing operation in respect of which a licence is required under this Regulation shall develop and implement a written plan with respect to the recall of fish products to ensure the timely and effective recall of any fish product distributed by the operation.
      2. The operator shall periodically evaluate the effectiveness of the recall plan required under subsection (1), including whether fish products can be effectively identified and recalled in a timely manner.
      3. If a periodic evaluation required under subsection (2) determines that the recall plan does not provide for the timely and effective identification and recall of fish products, the operator shall immediately,
        1. amend the recall plan; and
        2. evaluate the effectiveness of the amended recall plan, including whether fish products can be effectively identified and recalled in a timely manner.