Traceback and Product Recall
A recall is the procedure(s) conducted by responsible handlers to remove or correct a product that regulatory authorities consider – or may consider – to be in violation of their food laws.
Traceback is the ability to track almonds back to their source (growers, huller/shellers, etc.). A system to identify the source of almonds cannot alone prevent food safety problems or the occurrence of a food safety recall. However, the ability to identify the source of a product through traceback serves as an important component of good agricultural and manufacturing practices and may prevent the occurrence of food safety problems. Information gained from a traceback investigation may also be useful in identifying and eliminating a hazardous pathway. The minimum regulatory requirement is the ability to trace all food products forward one level in the supply chain and back one level in the supply chain. This action must be completed within twenty-four hours of notification.
A product recall is a voluntary action initiated by a handler to remove product that regulatory authorities consider to be in violation of their food laws. No handler wants to face a product recall. However, an established product recall program is invaluable should a food safety problem occur. Recalls are procedures used to identify and recover potentially adulterated, misbranded, and/or hazardous foods in order to prevent potential food safety problems.
Prompting a recall
There are many situations that can result in a food product recall. Some are emergency situations; others are not. Following is a list of potential causes of recalls involving almonds and almond products.
- Allergens – A product or component containing an unlabeled ingredient that may cause an allergic reaction in humans (Almonds and other tree nuts are included on the FDA’s list of common allergens).
- Bacterial contamination – Contamination by spoilage organisms or harmful bacteria (E. Coli, Salmonella, Listeria, etc.).
- Chemical contamination – Presence of unapproved pesticides and/or residues of these items in amounts greater than the established residue tolerance levels. Naturally occurring chemical contaminants such as Aflatoxin.
- Communicable diseases – Human illnesses that can be transmitted through foods.
- Handler generated information – Food safety problems discovered through handlers internal record review and examination processes.
- Foreign materials – Presence of glass, plastic or metal.
- Illnesses identified by food safety regulators.
- In-house sabotage.
- Misbranding – Violations of labeling laws.
- Real or fraudulent customer or consumer claims.
- Tampering and tampering threats.
- Undeclared ingredients.
A Class I recall means there is a reasonable probability that the use of the contaminated product will cause serious adverse health consequences or death. Examples of Class I recalls are:
- Salmonella Contamination.
- Undeclared Allergens (the presence of other tree nuts in almonds).
A Class II recall means the use of a contaminated product may cause temporary or medically reversible adverse health consequences. Examples of Class II recalls are:
- The presence of spoilage organisms.
- The presence of unapproved additives or ingredients.
A Class III recall is for products that violate federal regulations but are unlikely to cause adverse health consequences. Examples of Class III recalls are:
- Mislabeling such as incorrect weight declaration or non-organic almonds being labeled as organic.
- Almonds produced under unsanitary conditions.
Handlers responsibilities to their customers
When communicating recall information to customers, it must accurately reflect the level of danger that may be involved in using the product, as well as a strategy developed for the recall. By law, the recall communication must include the following details:
- The complete identity of the product, along with labels, brand name and code number information.
- The product is being recalled.
- The “further distribution or use of any remaining product should cease immediately.”
- That this customer should notify any of its own customers, down the line, if they received any of the product.
- Specific instructions for what to do with the product.
- It should also include a ready means for the customer to report back to the company. The FDA suggestions are:
– A self-addressed postage paid postcard, or
– A phone number for customers to call, collect or toll-free.
– The law says this information can be imparted by telegram, mailgrams, or first class letters conspicuously marked, preferably in BOLD RED TYPE, on the letter and envelope “FOOD RECALL.” For Class I & II recalls it should also be marked “URGENT.”
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