Product Recall

The purpose of product recall is to remove affected products from the market or temporary removal for product correction. After product correction, products may be returned to the market for sale.

For example, When a company faces a situation as mentioned above, they would have to recall the product. There are several steps that should be taken. The first is to appoint a recall committee. The size of the committee depends on the size of the company concerned, and they should have executive powers in the crisis. The committee should comprise of employees with expertise in these areas: Regulatory, Production & Sales, Quality Control, Public Relations, Legal, Purchasing and top management of the company.

After that, the committee shall based on the seriousness of the incident and classified as Class 1,2 or 3.

Class 1

There is a reasonable probability that the use of the product will cause serious adverse health effects, or even death. In this case, the organisation should conduct an immediate & rapid recall of all affected products or raw products, where possible (including the ones that are still under the company control). The company shall notify the local authorities such as Health Science Authority (HSA) and the media about this product recall.

Class 2

This is when products may cause temporary or medically reversible health consequences to the health of consumers when ingested. In this case, there should be an immediate and rapid recall of all affected products, including those under the company’s control. Secondly, the company should hold all suspected raw materials and notify media and local authorities.

Class 3

This is when the product is not likely to cause adverse health consequences, but violate some specific food regulation. In this situation, there is a need to recall all the affected products, where possible (including those under the company’s control). The company shall hold all suspected raw materials where relevant. There is a need to inform the local authorities; however, notification of media is not required.

Actions Taken

After the committee has decided the type of recall, they would then have to take actions such as determination of the suspected product identification codes, the date of manufacture, handling of the media and public consumers’ enquires, as well as documentation of relevant records. These are the things that might be helpful for investigations and a list of the recall committee contact details should be given to the local authorities when there is a need for investigation. The main objective of the product recall is to withdraw and isolate the specific product within the production and in the market within a short period of time.

For instance, in the production department, the Head (F&B Manager) shall announce the stopping of all production in the establishment. The suspected defected product and raw materials shall be labelled and quarantined until the entire investigation ends. The company will prepare a press statement and inform the consumers about the product recall and clear directions would be given to them. A 24-hour telephone hotline will be opened up and trained personnel from the PR department would answer enquires by the public consumers and media.

Before the media releases the product recall, the sales and marketing department should have drawn up the distribution list of where the affected products are. The department must contact the relevant distributors or retailers through verbal communication, followed by a recall letter. Instructions will be given to them on what they should do to the product such as the collection of the recalled products. Regular meetings are needed to update each other on the actions taken with regards to the product recall and preparation for the investigation of the product defect. The contents of the meeting shall be recorded on a regular basis and documented for reference to the company itself and to local authorities for investigations and back-tracking purposes.For the investigation of the product, the Production Department and the Quality Control Department will work together to find out the source of the product defect. After the investigation has taken place, the Quality Control Department will then write up a report stating the source of contamination such as type of contamination (physical, chemical, biological) or other areas such as hygiene issues. The results of the investigation will be revealed to the local authorities and the media.

Lastly, the recall committee will discuss the aftermath of the incident. The discussion will include the quantity of raw ingredients and defect products disposed, the sales loss of the company, the follow-ups taken (such as any change of raw ingredient, training of production line staff on hygiene, changes to be made of the current SOP or GMP etc.), marketing strategies to regain consumers’ confidence after the product recall incident and lastly, the reflection of the effectiveness of recall committee. After that, the content of the meeting shall be summarising as a report. The report will then be submitted to the top management for approval and to local authorities. In addition, a full recall report (refer to appendices) must be submitted to the local authority, HSA’s Enforcement Branch recall officer within 3 weeks from the date of initiation of recall.


Posted by: Nicholas Tan