0.6 Food safety: introduction to incident management  (Page 4/4)

If there is an incident, an effective complaint handling system will provide you and your colleagues with vital information, allowing you to accurately assess the risk and thus take appropriate action. Being proactive in handling complaints means that you must identify the severity and the significance of the complaints.

All companies within the supply chain should have effective procedures for handling complaints and understand how information gathered relates to product safety and their customers. These procedures should be fully documented with specific personnel trained to handle them. There should be an individual available at any time within each organisation who is responsible for dealing with serious complaints.

Consumers tend to complain directly to the brand owner or to the organisation who sold the product to them. Thus there is a shared responsibility for the assessment of complaints in determining their source and importance. Since you are the person responsible for dealing with complaints, you must fully understand your customers’ needs.

Required action

All complaints are important. There should be a procedure in place which specifies

• who is responsible for dealing with complaints
• how a complaint is investigated
• how a complaint investigation is reported and, where appropriate, information about the investigation is provided to the complainant
• how much time is required to investigate and to document (or report ) on the outcome of the investigation
• how complaints are reviewed.

The regular review of complaints is a useful practice to help you understand the performance of your food safety management system and to identify any potential hazards which you may be unaware of.

Product quarantine

A product may be quarantined for a number of reasons:

• You have identified that the product is unsafe.
• You have identified that the product is potentially unsafe and is being held pending further investigation or checking before a decision can be made.
• A product has been returned from a customer and thus should not be used.

Quarantine means that the product is held under secure conditions to ensure that it is not used or dispatched. Under no circumstances can it be used until authorization for its movement or use is given by an appropriate person.

If you are the person responsible for food safety, it is important that you be fully aware of the quantity, condition, and status of all quarantined products under your control.

Required action

Once a product has been placed in quarantine, under no circumstances should it be used, or dispatched, without authority by an appropriate person.

Factories are busy places. Preferably quarantined products should be physically isolated to a clearly-designated area where access is restricted to employees authorized to enter this area.

In many factories, however, this is not normally the case; so the product must be clearly marked or identified as being quarantined and employees must be trained to recognize the product status and the significance if the product is used or dispatched. It is advisable that all quarantined products be physically marked with very recognizable colored labels, marks, or symbols which are not easily removed. (Products should be marked even if placed in designated quarantine areas).

You should be fully aware of any possibility that the quarantined product could be accidently used or dispatched by employees or staff and introduce procedures to minimize the risk of such happening. This process should involve key staff/employees who are handling, storing, or dispatching the product.

Product recall

Product Recall

The process by which a product is removed from the market, where the product has reached consumers and they are advised to return or destroy products supplied to them.”

The Codex Code of Practice - Recommended International Code of Practice General Principles of Food Hygiene Cac/Rcp 1-1969, Rev. 4-2003 states,

Managers should ensure effective procedures are in place to deal with any food safety hazard and to enable the complete, rapid recall of any implicated lot of the finished food from the market.

Where a product has been withdrawn because of an immediate health hazard, other products which are produced under similar conditions, and which may present a similar hazard to public health, should be evaluated for safety and may need to be withdrawn. The need for public warnings should be considered.

As the person responsible for food safety, the development and maintenance of product recall procedures rests with you. You must gain the cooperation and commitment of your management and colleague so that when a serious problem arises you have full support to deal authoritatively and effectively with the situation.

In operation, the product recall process is complex and will become more complex as a company grows and the number of customers increases, but the principles that should be in place to support an effective product recall are relatively simple.

Procedures

As with the development of any procedure, you must carefully define

• who
• what
• how
• when.

Procedures must be documented. They must focus on consumer safety at all times. Key operations are

• restriction of any further unsafe products entering the supply chain
• the accuracy of information regarding the location of unsafe products
• the accuracy of information regarding your customers
• the operational method for communicating with your customers and other interested parties.

Since customer safety is paramount, you should make provision that you or a trained deputy be available at all times. It is also important that the procedures put in place must be followed at all times.

Communication

Good communication is vital to ensure that the safety of consumers is not compromised.

There are three important principles for effective communication in incident management:

1. There must be well-defined communication pathways.
2. Communication must be accurate and easily understood.
3. Communication processes must be fast and effective.

In a product recall, speed and accuracy of communication are vitally important. Customers should be contacted without delay.

Communication is a two-way process, so you need to confirm your company’s contact data to your customers and suppliers. You should have access to your emergency contact list at all times, allowing communication at any time. All contact data (your company, customers, and suppliers) must be accurate, and there must be a defined procedure in place to maintain the currency of this data.