While most Canadian food producers know that they are required by the SFCR to have a documented recall procedure, many do not realize that they also are required to conduct a recall simulation at least once a year – and to document the details and results of that simulation. (SFCR Part 4, Division 5)
What the regulation doesn’t detail, however, is how a recall simulation should be conducted. Beyond stating that the simulation is to be based on the recall procedure which “enables the effective recall of a food,” the regulation leaves a lot open to interpretation. And the industry’s interpretation of the simulation is, all too often, thought to be the same as a traceability exercise.
While it is important to conduct regular traceability/mass balance exercises to numerically test your system, that activity is not the same as a recall simulation. Rather, best practice is to literally simulate a recall, conducting a mock recall based on a created scenario, while following the CFIA recall guidance.
- Create a scenario. Set the scene, based on an incident that could occur for your company. For example, your company receives complaints about a person who became ill after consuming your product; you’re notified by a supplier that an ingredient is contaminated; a CFIA inspection identifies an issue requiring a recall, etc.
- Assemble the recall team. Include all departments – food safety and quality assurance, plant management, operations, purchasing, legal, marketing/communications, etc.
- Test your system. Run through your full recall procedure based on the created scenario, including a full tracking and tracing of the affected food product(s), setting holds for those still in your control and determining quantity, location, etc., of others.
- Simulate your communications to CFIA, suppliers, customers, consumers. Do you have templates created to ensure speedy communication? Who will speak to the media? Are they prepared?
- Note: When testing recall systems with outside partners (e.g., clients, suppliers), extra caution needs to be taken to ensure any communication is not mistaken as a real situation. It is often better not to send anything electronically to external parties about a mock recall to avoid this.
- Document the simulation. As required by the SFCR, prepare a document that details how the recall simulation was conducted and the results. Retain the documentation for two years.
- Analyze the effectiveness of the simulation. How quickly were you able to conduct the recall? Did team members know their roles and responsibilities? Was all product able to be traced and held? What worked well? What needs to be improved?
While tracing product is an integral part of a recall, there is much more to a recall than that, thus the recall simulation also needs to focus on more than just the tracing of the product. While the above outline provides a general look at conducting a mock recall, it can be beneficial to involve an external person who can look at your operations in an objective way and provide recommendations for continuous improvement.
The TAG Canada team understands CFIA regulations and is experienced in the recall process. Give us a call for assistance.