By Ms Ria Bhadra
Consumer brands gain confidence and trust from consumers with the delivery of safe, correctly labelled and good quality food products. Food processors constantly thrive to ensure that food safety and quality is maintained through all the phases of processing which initiates from responsible sourcing, handling and storage of raw materials, processing of the food and ends until the food product is delivered to the consumer and is safe for consumption as well as storage under the recommended conditions. Owing to the perishable nature of foods, it becomes very difficult to assure that under no circumstances should the food be exposed to conditions or environment which can contaminate the food. Hence, food safety does reside in the interface of risk management as well as supply chain management of any food processing firm. As discussed, food products are delicate and have high risks of contamination and the contaminated foods could pose different levels of severities of cases which could result to huge losses for the food producers. In such cases, depending upon the severity, food manufacturers take an action to remove the food product from all levels of distribution, sale and consumption as early as possible. This is known as a food product recall process.
There could be various reasons of a food product recall. Few of them could be related to microbial/chemical contamination, an undeclared allergen, foreign matter contamination, inappropriate labelling, misleading claims on the product etc. A recall could be either requested from a food processor on discovering such a defect or it could be initiated by the regulatory agencies based on consumer complaints. Irrespective of how profoundly the food has been distributed through the distribution network, the food product must be completely removed from the entire system.
In order to counter such uncertain recall issues effectively, it is highly important that food businesses establish a proper food recall system. Based on the extent of distribution, there are broadly two levels of recall: trade level recall and a consumer level recall
Trade level recall is when the product has not been distributed at consumer level or is not available to the public for purchase, such as the caterers or wholesalers. A consumer level recall is when the food is intended for a retail sale.
Based on the severity of food recalls, there are three categories: Class 1, 2 & 3 Recalls
In a situation where the probability of use or exposure to the product could cause serious health effects or deaths is categorized as the Class 1 Recall. In the case of a temporary or medically reversible condition, it is categorized as the Class 2 Recall. In the case where the use or exposure to a product does not likely cause any health adversities, it is categorized as the Class 3 Recall.
In India, FSSAI has issued guidelines on developing and implementing a food recall plan for food businesses. It is mandatory for the food business operators to follow the guidelines during the event of such a recall failing which the esteemed body could take an action against the food business operator under the act, rules and regulations made thereunder.
A complete recall plan has the general steps to follow as mentioned below:
- Recall management team to take responsibility of coordinating the entire recall process.
- Notification to the Food Authorities and targeted customers in the form of a paid advertisement or press release
- Identification of the food product (batch/lot/variant etc.) to be recalled
- Recovery of the product
- Checking the effectiveness of the recall
- Submission of a post recall report to the Food Authority
- Termination of the recall and steps taken on prevention of such occurrences in the future
A food processor is required to maintain the food distribution records including the product details, its nature, delivery date, lot & batch number, date of manufacture, expiry date, names of suppliers/customers, pack size etc. for a specified period of time. In case of any food recall event, the food business operator must alert at all the levels of distribution network by the quickest means of communication such as email, telephonic/radio announcements, online/social media etc. in order to immediately proceed for the returns of the sold goods.
These returns could be at levels ranging:
- From customers to retailers, retailers to traders, traders to the distribution channels and then to the food producers.
- Returns directly from customers to the food producers.
India being one of the largest food producers faces a threat to such food recalls due to the abundance of multiple and geographical spread of raw material suppliers, processing units and online food retailing. The lack of a proper traceability system could worsen the scenario during a food recall. The clarity of how many batches/lots are affected, the scope of the food recall process and at which level of the supply chain the food product has reached are the common areas where the food business operator is expected to be detailed with. There have been numerous food recall events in the past ranging from serious disease outbreaks after consumption of contaminated foods to mislabeling of the pack and the level of damage varies from one firm to the other based on how strong the traceability system of the organization is.
Besides huge financial losses, the consumer trust that takes a long time to build also gets affected during such an event associated with a food manufacturing firm at the incapability of maintaining proper food processing operations and functions.
The events of such food product recall incidents should therefore be tried to be minimized at the food processing level itself, as we say, “Prevention is better than cure”. Few are some of the approaches which the food processing firms should obey and religiously follow in order to avoid/reduce the likeliness of occurrences for such food recalls:
- An effective GMP (Good Manufacturing Practices) program
- A proper traceability system
- Suitable HACCP plans
- Appropriate sampling plans and testing frequencies of incoming raw materials, swab tests of workmen and food processing equipment etc.
- A proper GHP plan
- Proper manufacturing procedures and process control
- In process control and records of raw material supplies, processing parameters and finished products
- Proper raw material storage
- Implementation of 5S in the food production facility
The author is in Tasty Bite Eatables reached at bhadraa.ria@gmail.com
