Impression Europe Recall Policy March 2017
In the event that a food safety issue arises with our products Impression Europe will protect public health by facilitating the efficient, rapid identification and removal of unsafe food from the distribution chain and, by informing consumers of the presence in the market of food which is potentially unsafe/and or injurious to health.
If the circumstances require, we will both notify and endeavour to work quickly with our local authority in order to carry out a product recall. Our recall procedure is documented and will be fully accessible to Essex Trading Standards Department.
This procedure states the action/s Impression Europe will take to effectively manage the recall of a food which has been determined to be unsafe or unsuitable.
There are two levels of product recall, these are as follows:
Recall (also known as a consumer level recall): This is a removal of unsafe food from the distribution chain and extends to food sold to consumers and therefore involves communication with consumers.
Withdrawal (also known as a trade level recall): This is the removal of an unsafe food from the distribution chain but does not extend to food sold to the consumer.
An effective product recall will ensure that the unsafe or unsuitable food/s is contained and either destroyed or made safe.
Roles and Responsibilities
Initially, following complaint information, a risk assessment of the product would take place. This would be combined with notifying Essex Trading Standards department and discussing whether a product recall is necessary. It is Impression Europe’s responsibility to effectively organise and manage the recall of food that has been demonstrated to be unsafe or unsuitable. The recall co-ordinator is Michael Hearn, who has been given authority from management to make recall decisions on behalf of Impression Europe.
Trading Standards wishes to work with us in our recall action and thus be satisfied that we are taking all reasonable steps to protect consumers. When a recall is initiated, our actions in recalling the affected food/s will be co-ordinated and communicated with both Trading Standards and the Food Standards Agency. There will be full disclosure of all information to the FSA and Trading Standards regarding the supply chain, the affected products and the product recall.
Recall Co-ordinator Michael Hearn will contact the below, if he is absent from the office at any time then the directors Adrian and Malcolm Stephenson will co-ordinate.
Essex Trading Standards (Essex County Council, Trading Standards, CG32, County Hall, Market Road, Chelmsford CM1 1QH, telephone 0845 6037626, email: Trading.Standards@Essex.gov.uk),
The Food Standards Agency (Aviation House, 125 Kingsway, London, WC2B 6NH, Incidents Response Team, Tel: 020 7276 8448, Email: firstname.lastname@example.org
Other relevant bodies will be notified, such as Environmental Health Department, Allergy UK etc.
Identified product/batches etc. will be traceable and traceability records of customers (retailers/wholesalers etc.) will be maintained as required by EC Regulation 178/2002/EC.
- Food must not be unsafe
- Labelling, advertising and presentation of food must not mislead
- Food businesses must be able to trace where food has come from and where it has been sold to
- Unsafe food must be withdrawn from sale or recalled from consumers if it has already been sold
A full distribution list of customers (retailers/wholesalers and if known – consumers) will be compiled along with details/quantities of affected products supplied.
Records of contact with customers will be maintained – details of actions taken/products returned/destroyed etc. and follow up contact by phone/email should be made.
It is our responsibility to manage the recall by clarifying the food safety issue and the exposure (who and where risk exists), and to provide details on distribution and the method of recall.
Trading Standards are available to provide support and technical advice via the Officer co-ordinating the recall.
Duties of the recall Co-ordinator are;-
- Assess the overall problem;
- Notify the relevant regulatory authority;
- Evaluate the food which is unsafe and/or injurious to health and the extent of contamination;
- Determine a strategy to be followed;
- Make decisions about product still in storage with the supplier;
Recall Actions & Documentation
The recall Co-ordinator shall reference and follow the actions outlined when he/she becomes aware a product may be unsafe or unsuitable. They will ensure that records of all actions and decisions and who was responsible are recorded and retained.
Decision to Recall
The decision on whether to recall or withdraw a product/s or not will be based on the identification of a hazard that makes a foodstuff unsafe and its likelihood of affecting public health. Where food has reached the final consumer, a recall will be required as opposed to a withdrawal. This will be determined by careful, considered risk assessment by Impression Europe after liaising with the supplier and receiving assistance and advice through Trading Standards.
Scope of Recall
The scope of a recall is a very important part of the process; other batches should be tested/analysed if not initially recalled to assess the extent of the problem.
Notification of a product recall
If the decision is taken to initiate a Withdrawal we will notify:
- Senior management of Impression Europe, supply chain personnel
- Trading Standards
- Any distributor that has received this product from the batch supplied
- The supplier of the food must be notified as other distributors may need to be contacted regarding recall of affected products.
Notification – contacts should be notified by phone, email, letter, or any other appropriate means.
Recall Notices should be sent out if in recall premises, the policy is also available on our company website.
We will also supply details for the following:
- The supplier of the product
- Ingredients for that product
- The correct certification for that product that conforms to current EU legislation
Regaining control of affected stock;
All affected stocks held by the relevant company should be segregated/quarantined and clearly identified to prevent their supply. Likewise with any returned product as a result of the recall.
Arrangements will be made with customers for the safe collection/return or disposal of affected product if appropriate.
If affected stock is directed to be returned to us then the recovered product/s will be checked and returned to the supplier for assessing. Accurate records will be kept of the amounts recovered and the codes of the product/s. If the recovered product/s is unfit for human consumption, it may be destroyed or denatured by the supplier after investigations by the correct regulatory bodies.
The recall procedure will be reviewed annually and will be tested and documented, it is also available on our company website.