Food recall response playbook

Ten steps for a recall in Canada or the United States, each with the regulatory reference behind it. Work down the list during an event and use the same list for your mock recall.

1. 1. Assemble the recall team and assess the situationConvene the recall team named in your written recall procedure, record the trigger (complaint, test result, regulator contact, supplier notice), and document what is known and unknown at this point.

   Canada

   SFCR s. 84 (recall procedure)Legal requirementA licence holder must prepare, keep and maintain a written recall procedure that identifies the person responsible for recalls, describes how affected food is identified and controlled, how the Minister and affected parties are notified, and how the recall is carried out. The procedure must be tested at least once a year and records kept for two years.SFCR s. 85 (complaints)Legal requirementA written complaint procedure covering receipt, investigation and any resulting action, with records kept for two years.

   United States

   21 CFR 117.139 (recall plan)Legal requirementA written recall plan is required for a food with a hazard requiring a preventive control, and must describe notification of consignees, public warning where appropriate, effectiveness checks and disposition of recalled food.

2. 2. Decide whether the product presents a health riskPerform a documented health-risk assessment: hazard identity, exposure, susceptible populations, and severity. Record the reasoning and who made the decision — this drives recall urgency and how it is classified.

   Canada

   CFIA recall guidanceRegulatory guidanceCFIA explains how it expects recalls to be reported, classified and communicated, and it issues the public food recall warning. Guidance helps you prepare; the regulation is what binds you.

   United States

   21 CFR Part 7, Subpart C (recall policy)Legal requirementFDA's recall policy: recall classification, public warnings, recall communications, status reports and termination of a recall.

3. 3. Define the scope with traceability recordsUse your one-back / one-forward traceability documents and lot identification to bound the affected lots: production dates, code ranges, quantities produced, shipped, on hold and returned. Reconcile quantities so the total is accounted for.

   Canada

   SFCR Part 5, beginning at s. 90 (traceability)Legal requirementPart 5 sets traceability obligations: documents identifying food received and provided (one back, one forward), the information those documents must contain, lot identification, and how long the documents must be kept and how quickly they must be provided.SFCR s. 90 (traceability documents)Legal requirementTraceability documents must be prepared and kept for food that is sent or conveyed, imported, or received.SFCR s. 93 (lot identification)Legal requirementPrepackaged food must bear a lot code or other identifier that allows it to be traced.

   United States

   21 CFR Part 7, Subpart C (recall policy)Legal requirementFDA's recall policy: recall classification, public warnings, recall communications, status reports and termination of a recall.

4. 4. Stop distribution and control inventoryPlace affected and suspect lots on hold, halt shipment, and physically segregate and label held product so it cannot be released in error.

   Canada

   SFCR s. 47 (hazard identification and control)Legal requirementBiological, chemical and physical hazards that present a risk of contamination must be identified and prevented, eliminated or reduced to an acceptable level, using measures shown to be effective.SFCR s. 48 (monitoring, corrective action, verification)Legal requirementControl measures must be monitored, corrective action taken on deviation, and the effectiveness of the measures verified.

   United States

   21 CFR 117.135 (preventive controls)Legal requirementPreventive controls must be identified and implemented as appropriate to the facility, the food and the nature of the hazard — which may include process, food allergen, sanitation, supply-chain and other controls.21 CFR 117.150 (corrective actions and corrections)Legal requirementWritten corrective action procedures are required where a preventive control is not properly implemented, including identifying and correcting the problem, reducing recurrence, evaluating affected food and preventing adulterated or misbranded food from entering commerce.

5. 5. Notify the regulatorContact the regulator without delay with product identity, the hazard, distribution scope, quantities and your proposed action. Keep a record of who was contacted, when, and what was submitted.

   Canada

   SFCR s. 84 (recall procedure)Legal requirementA licence holder must prepare, keep and maintain a written recall procedure that identifies the person responsible for recalls, describes how affected food is identified and controlled, how the Minister and affected parties are notified, and how the recall is carried out. The procedure must be tested at least once a year and records kept for two years.SFCA s. 15 (duty to provide information / recall)Legal requirementThe Act sets out obligations to provide information to the Minister and supports the Minister's power to order a recall.

   United States

   FDA Reportable Food Registry (24-hour report)Regulatory guidanceA responsible party must report a reportable food to FDA through the Reportable Food Registry within 24 hours of determining that a food presents a reasonable probability of serious adverse health consequences.

6. 6. Notify customers and consigneesIssue written notification to every direct consignee with product identification, the reason, the action requested, and a response deadline. Track responses so you can show the reach of the notification.

   Canada

   SFCR s. 84 (recall procedure)Legal requirementA licence holder must prepare, keep and maintain a written recall procedure that identifies the person responsible for recalls, describes how affected food is identified and controlled, how the Minister and affected parties are notified, and how the recall is carried out. The procedure must be tested at least once a year and records kept for two years.

   United States

   21 CFR 117.139 (recall plan)Legal requirementA written recall plan is required for a food with a hazard requiring a preventive control, and must describe notification of consignees, public warning where appropriate, effectiveness checks and disposition of recalled food.21 CFR Part 7, Subpart C (recall policy)Legal requirementFDA's recall policy: recall classification, public warnings, recall communications, status reports and termination of a recall.

7. 7. Public communication where requiredWhere consumer-level product is affected, prepare the public warning with the regulator: product photos, UPC and lot codes, the hazard described in plain language, and what consumers should do.

   Canada

   CFIA recall guidanceRegulatory guidanceCFIA explains how it expects recalls to be reported, classified and communicated, and it issues the public food recall warning. Guidance helps you prepare; the regulation is what binds you.

   United States

   21 CFR Part 7, Subpart C (recall policy)Legal requirementFDA's recall policy: recall classification, public warnings, recall communications, status reports and termination of a recall.

8. 8. Verify effectivenessPerform effectiveness checks against your consignee list until you reach your defined threshold, and record the disposition of recovered product (return, destruction, rework) with quantities. The same workflow is how you run and evidence your annual recall simulation.

   Canada

   SFCR s. 84 (recall procedure)Legal requirementA licence holder must prepare, keep and maintain a written recall procedure that identifies the person responsible for recalls, describes how affected food is identified and controlled, how the Minister and affected parties are notified, and how the recall is carried out. The procedure must be tested at least once a year and records kept for two years.

   United States

   21 CFR Part 7, Subpart C (recall policy)Legal requirementFDA's recall policy: recall classification, public warnings, recall communications, status reports and termination of a recall.21 CFR 117.139 (recall plan)Legal requirementA written recall plan is required for a food with a hazard requiring a preventive control, and must describe notification of consignees, public warning where appropriate, effectiveness checks and disposition of recalled food.

9. 9. Root cause analysis and corrective actionInvestigate to true root cause (not just the failed lot), correct the system, and reassess the hazard analysis and the controls that failed to prevent it.

   Canada

   SFCR s. 48 (monitoring, corrective action, verification)Legal requirementControl measures must be monitored, corrective action taken on deviation, and the effectiveness of the measures verified.SFCR s. 86 (written preventive control plan)Legal requirementWhere required, the licence holder must prepare, keep and maintain a written preventive control plan describing the hazards, control measures, monitoring, corrective action and verification for the food and activity.

   United States

   21 CFR 117.150 (corrective actions and corrections)Legal requirementWritten corrective action procedures are required where a preventive control is not properly implemented, including identifying and correcting the problem, reducing recurrence, evaluating affected food and preventing adulterated or misbranded food from entering commerce.21 CFR 117.170 (reanalysis)Legal requirementThe food safety plan must be reanalysed at least once every three years, and sooner when a significant change, new hazard information, or an unanticipated food safety problem — including a recall — indicates it is needed.

10. 10. Retain the recall fileKeep the complete file: timeline, decisions and who made them, notifications, effectiveness checks, disposition records, and the corrective-action outcome.

    Canada

    SFCR s. 84 (recall procedure)Legal requirementA licence holder must prepare, keep and maintain a written recall procedure that identifies the person responsible for recalls, describes how affected food is identified and controlled, how the Minister and affected parties are notified, and how the recall is carried out. The procedure must be tested at least once a year and records kept for two years.SFCR s. 88 (preventive control records)Legal requirementRecords demonstrating implementation of the preventive control plan must be kept, and kept for two years.

    United States

    21 CFR 117.310 (records retention)Legal requirementRequired records must be retained at the plant or facility for at least two years after the date they were prepared.