The Food Recall Regulation of FSSAI, India: In Short

On 18 Jan 2017, FSSAI implemented FSS (Food Recall) regulation,2017 which mandates FBOs to have their own Food Recall Plan and follow a specific procedure for recalling the food whose safety is at risk which is as follows:

Introduction: 

The concept of recall actually originated from recall of vehicles in automobile industry which later extended to various manufacturing sectors including food. Food recall is nothing but the process of removing food product under question from all places where it had been distributed. It also includes consumers, which may have purchased it. This regulation is specifically  applicable to food having safety at risk. It is interesting to note that, the food recalled for any other reason does not fall under the purview of this regulation and hence FBO need not to follow the recall procedure as mentioned in the regulation.So as to make this process of food recall more effective, efficient and quick the regulation mandates FBOs to have their own strategy/emergency plan in a documented form. The Food Recall Plan is document which contains an action plan when there is an urgent need to remove the food product from market at any stage of food chain.Usually this plan is made as a part of Food Safety Management System Plan which is an another mandatory document required for obtaining Food License in India. This regulation have not provided any model food recall plan, but given guidelines on mandatory information that need to be present in a typical food recall plan as follows:

1.Names & address of Raw material Suppliers.

2.Name & address of Customers(B2B) which includes Wholesale distributors, retailers down the line.

3.Nature of food

4.Date of purchased

5.Date of delhi very

6.Lot number

7.batch code

8.Pack size

9.brand name

10.Date of Manufacture

11.Best before date/ Date of expiry

(1- 11 As applicable depending upon type of product.)

For the product like alcoholic beverages where date of expiry is not applicable, but FBO has to preserve the record of purchase at least for two years.

FOOD RECALL PROCEDURE:

The recall regulation of India mandates FBOs to follow the specific procedure so as to ensure the rapid and complete recall of product.The regulation basically gives standard protocol which is need to be followed for effective & efficient recall of food. The recall procedure is basically divided into three steps which is as follows:

1. Initiation of recall

In this step, FBO has to intimate concerned food authority about his intention to recall food. This intimation has to be made in the format as specified in Schedule-I of the regulation, within 24 hrs of realization of need for recall.FBO also needs to prepare a Food Recall Notice and circulate it throughout the distribution chain immediately.

This food recall Notice require to have following information:

(a) Name of the Food Business Operator recalling the food;

(b) Name of the food, brand name, pack size, batch and code number, date of manufacture, used by date or best before date;

(c) The contamination or violation in the food or reason for such recall;

(d) “do not consume message”;

(e) Health warning and action;

(f) The places or outlets where the food is found;

(g) The action to be taken by the consumer;

(h) Contact number for queries.

Decision to stop production is totally up to the discretion of FBO, till it is specifically ordered by Food Authority. If FBO realize that there is a need to stop the production, he should voluntarily do so without waiting for orders from food authority. But during the process of recall, FBO need to respond to every query raised by Food Authority within 24 hrs of receipt of query.

2. Reporting Recall Status:

In this step, progress report about effectiveness of recall is to be submitted to food authority in the format as specified in shedule-II of regulation. Normally, FBO needs to submit this status report once in a weak, but frequency of submission can be decided by food authority. It is important to note that , FBO needs to keep submitting the status report till food authority issues a termination letter for that perticular recall.

3. Termination of recall:

In this step the FBO needs to write a letter to food authority requesting termination of recall, only if FBO is confidant about effectiveness of recall. This request letter has to be made in the format as specified in Schedule-III of regulation. The request letter must be sent along with the Status report (Schedule-II) demonstrating the the effectiveness of recall. If Food Authority is convinced with effectiveness of recall and believes that food under recall has been removed and/or disposed appropriately, the recall can be terminated. FBO also has to show the evidences that the necessary corrective actions have been taken to ensure to avoid such incidents again.

On receipt of such request, Food Authority needs to reply FBO within two weeks of receipt. If Food Authority is not convinced about effectiveness of recall, a legal action can be is initiated against FBO.

FBOs Exempted from having recall plan:
1.The food retailers are not required to have a food recall plan, unless they are also engaged in the manufacture or importation or wholesale supply of food.
2.Food service sector such as restaurants, caterers and takeaway joints are exempted from having a recall plan unless they are running multi-outlet food business chains with integrated manufacturing and distribution network.


References:
www.fssai.gov.in
http://www.fssai.gov.in/home/fss-legislation/fss-regulations.html