Food recalls

Food Act 2008 (WA) fact sheet 14

Version 1 June 2014

Purpose

To provide information to Food Act 2008 (WA) (Food Act) authorised officers and food businesses on:

  • what constitutes a food recall
  • types of food recalls
  • roles and responsibilities when recalling food
  • the process of conducting a food recall.

Background

Food recall is defined in the Food Standards Australia New Zealand Food Industry Recall Protocol1 (the Protocol), as ‘an action taken to remove from distribution, sale and consumption, food which is unsafe’. There are many reasons why a food product can be recalled. The most common are microbiological contamination, undeclared allergens, the presence of foreign substances, packaging defects and labelling errors.

There are two clauses in Standard 3.2.2 – ‘Food Safety Practices and General Requirements’ of the Australia New Zealand Food Standards Code (the Code) that contain requirements relating to food recall. Guidelines on complying with these clauses can be found in the Protocol.

Clause 12 of Standard 3.2.2 applies to those food businesses involved in the wholesale supply, manufacture or importation of food, and requires these food businesses to:

  • have in place a system to ensure the recall of unsafe food
  • set out this system in a written document and make this document available to an authorised officer on request; and
  • comply with this system when recalling unsafe food.

Clause 11 of Standard 3.2.2 applies to all food businesses, when affected by a food recall, to ensure that food for disposal is held, separated and identified from other food, until it is:

  • destroyed or otherwise used for purpose other than human consumption
  • returned to its supplier
  • further processed in a way that ensure its safety and suitability
  • ascertained to be safe and suitable.

Types of food recalls

Food recalls can be managed on a case-by-case basis depending on various factors including risk to public health, level of compliance of the food business and distribution of the food product. Recall categories that have been defined in the Protocol are as follows:

Trade recall

A trade recall can be defined as a recall where food product is not available for direct purchase by the general public. In this case the food product is removed from distribution centres and wholesalers. This type of recall would also include recovering food products from hospitals, restaurants and other catering establishments where food is intended for immediate consumption.

Consumer recall

A consumer recall can be defined as a more extensive food recall, because it recovers the food product from all points, including recalled product in the possession of customers. The public must therefore also be informed of a consumer recall. Media such as newspaper advertisement is normally used as a communication tool.

Mandatory recall

In some rare cases, when a food product is at risk to public health and safety, and the food business is not voluntarily recalling the product from distribution, sale and / or consumption, a mandatory food recall will occur. This type of food recall is ordered by the Commonwealth or State or Territory government. The special provisions related to mandatory food recall orders are outlined in section 33 of the Food Act 2008.

Withdrawal

Different from a mandatory food recalls, a product withdrawal is defined as the removal of product from sale because of product quality defect or labelling irregularities which do not pose a risk to public health and safety. Product stock can also be withdrawn from sale pending additional investigation, which may eventually lead to a product recall.

Roles and responsibilities when recalling food

In terms of roles and responsibilities, there are several parties involved in the food recall process:

  • Food businesses including food manufacturers, importers and wholesalers have an important role in a food recall, because they are primarily responsible for removing the unsafe food product from sale. If the recalled food product reaches consumers, they have a responsibility to notify the public. To guide the food recall process, food businesses must have a clearly and effectively written food recall plan.
  • Food retailers are responsible for removing recalled food from sale.
  • Food Standards Australia New Zealand (FSANZ) food recall coordinator is a Commonwealth Government based role that has a range of responsibilities including:
    • Making sure that the food business responsible for initiating a food recall has access to the Protocol;
    • Liaising with State and Territory coordinators and other statutory authorities;
    • Reporting on the effectiveness of each recall, including corrective action; and
    • Providing reports and other relevant information to the Australian Competition and Consumer Commission (ACCC).
  • State and Territory Action Officers are responsible for collaborating with the FSANZ recall coordinator on recalls in their jurisdiction, for passing relevant recall action information on to the FSANZ recall coordinator, and for dissemination of food recalls. In WA, the State Action Officer is based in the Department of Health Food Unit.
  • Enforcement Agencies are responsible for investigating, coordinating and providing guidance to food businesses involved with a food recall in their district/jurisdiction.
  • Australian Competition and Consumer Commission has a responsibility to satisfy the Minister for Consumer Affairs that consumers have been protected as a result of successfully conducted product recalls. They regularly receive reports from FSANZ on all of the food recalls it coordinates.

The process of conducting a food recall

Each food recall is unique, may occur for different reasons and will require cooperation and communication of different authorities. The steps in conducting a successful recall however, are similar for all recalled food products and are as follows:

  1. Identify the problem associated with the food product
  2. Notify the appropriate regulatory agencies
  3. Identify all products that need to be recalled
  4. Separate and put on the hold all affected products that are in your control
  5. Prepare a distribution list
  6. Prepare a press release (if required)
  7. Notify customers (advise them what to do with recalled food)
  8. Control recalled products and decide what to do with them
  9. Dispose of recalled products, where applicable
  10. Fix the cause of the recall (i.e. re-labelling)
  11. Provide report to FSANZ recall coordinator stating the action taken to preclude a recurrence of the problem

For more detailed information on conducting a food product recall, and writing a food recall plan, please view the FSANZ food recall website (external site).

References

[1] Food Industry Recall Protocol – Information on Recalling Food in Australia and Writing a Food Recall Plan, 7th Edition May 2014, 2014 [cited 2014 June 5] (external PDF 1.86MB)

More information

Produced by

Public Health