According to the rule a Recall Plan is required when you have a hazard that requires a Preventive Control. 21 CFR 507.38 states:
- (a) For animal food with a hazard requiring a preventive control you must:
- (1) Establish a written recall plan for the animal food; and
- (2) Assign responsibility for performing all procedures in the recall plan
- (b) The written recall plan must include procedures that describe the steps to perform the following actions as appropriate to the facility:
- (1) Directly notify direct consignees about the animal food being recalled, including how to return or dispose of the affected animal food;
- (2) Notify the public about any hazard presented by the animal food when appropriate to protect human and animal health;
- (3) Conduct effectiveness checks to verify the recall has been carried out; and
- (4) Appropriately dispose of recalled animal food, e.g., through reprocessing, reworking, diverting to another use that would not present a safety concern, or destroying the animal food.
Recalls may be due to feed safety concerns or feed quality issues; they may be mandatory or voluntary. During PCQI training Chapter 10 taught us the 3 classes of recalls and the requirements of each type of recall. Simply stated, a recall plan is a well thought out series of steps and pre-assigned responsibilities to carry out the steps before the recall occurs. The plan should be practiced periodically, referred to as a “mock recall”. When a real recall occurs, all employees understand their responsibilities and can quickly and decisively carry out the plans step to implement the recall with little or no issues or safety concerns.
A solid plan will define details of each step in the recall process and person responsible for each item
- Scope of recall by identifying the feed involved, the hazard associated with the feed, including the likely class the recall will fall under.
- Regulatory agency communication, who needs to be notified: federal and/or state, when they need to be notified and how they will be notified.
- Recall initiation
- Customer notification
- Information and data compilation
- Document gathering
- Securing inventory of affected lot(s) in your control
- Product disposition
Recalls may be short and simple, for example, one lot of bulk feed delivered to one customer. The issues may be identified early, and all the feed may be able to be retrieved without adverse consequences to any animal.
Recalls may be lengthy and more complex. Maybe the feed was bagged and sold to multiple customers and/or resellers. Maybe the issue was not recognized until all the feed is delivered into commerce and it is more difficult to locate all the feed involved.
Whatever the situation, a well-designed and practiced plan will make the recall proceed more efficiently than one that must be defined as the situation unfolds.
An example plan is included in the materials distributed during training, I encourage you to make it your own.