Food recall - The current scenario in India

Introduction

Food recall is an effort to limit liability for food business operators’ (FBO) negligence and avoid damage to publicity.

Recalls are costly because they often entail replacing the recalled product or paying for damage caused by use, although possibly less costly than consequential costs caused by damage to brand name and reduced trust in the manufacturer. Despite the undesirable nature of a recall event, it is in the best interest of the FBO to complete the recall quickly. Because the FBO is responsible for all of the costs involved in this process, it is critical to have a plan to cover recall expenses, to expedite the process without creating negative public opinion.

The increasing occurrence of food-borne illness due to consumption of unsafe food and frequent food recall incidences appearing in the media have emphasised the need for an organised and systematic approach to food recall. This will save the consumers from unsafe food leaving the premises of the company and immediate recall / withdrawal of implicated food from the food chain to save the company from disrepute and economic loss. Food manufacturers strive to prevent a recall, employ Food Safety Management Systems (ISO 22000), Good Manufacturing Practices (GMP) and Hazard Analysis Critical Control Points (HACCP) plans. It is important to be ready for a recall well before a problem occurs. 

The Codex Alimentarius Commission (CAC), a joint FAO and WHO commission, in 1969 stipulated that “Managers should ensure effective procedures in place to deal with any food safety hazard and to enable the complete and 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 Where a product has been withdrawn because of an immediate health hazard, other products which are produced under similar conditions, and which may present a similar hazard to public health, should be evaluated for safety and may need to be withdrawn.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. Recalled products should be held under supervision until they are destroyed, used for purposes other than human consumption, determined to be safe for human consumption, or reprocessed in a manner to ensure their safety.

While food recall in India is a relatively new concept, the advent of Food Safety and Standards Act, 2006, brought to focus this vital aspect. Awareness is growing and FBOs are looking at it as a vital link in the supply chain. Indian companies are slowly realising that the product they release in the market may need to be recalled causing enormous damage to the reputation, brand name and loss of brand relevance and economic loss. This can be minimised if the company’s recall system is well planned, implemented and understood by those who are involved in core activities of sourcing, manufacturing and distribution functions.

International scenario

The Hazard Analysis and Critical Control Points (HACCP) brought out in 1997 by Codex Alimentarius Commission included food recall provision. It was widely implemented by food industries through certificate around the world. Also the International Organisation for Standardisation (ISO) brought out a more comprehensive international standard ISO 22000 on food safety in 2005 which provided requirements for product withdrawal / product recall (See Box 01).

Withdrawal / Recall Requirements

To enable and facilitate the complete and timely withdrawal of lots of end products which have been identified as unsafe by appointing personnel having the authority to initiate a withdrawal and personnel responsible for executing the withdrawal, and the organisation shall establish and maintain a documented procedure for product recall.

Withdrawn products shall be secured or held under supervision until they are destroyed, used for purposes other than originally intended, determined to be safe for the same (or other) intended use, or reprocessed in a manner to ensure they become safe.

The cause, extent and result of a withdrawal shall be recorded and reported to top management as input to the management review. The organisation shall verify and record the effectiveness of the withdrawal programme through the use of appropriate techniques (e.g. mock withdrawal or practice withdrawal). 

Current status for food recall in India

The Food Safety and Standards Act, 2006 

The Act under Section 28(4) emphasises the need for product recall. This states that if an FBO considers or has reasons to believe that a food which he / she has processed, manufactured or distributed is not in compliance with food safety norms he / she shall immediately initiate the procedures to withdraw the food in question from the market and consumers indicating reasons for its withdrawal and inform the competent authorities.

The Food Safety and Standard (Recall of Unsafe Food) Regulations

For effective implementation of the provision on food recall, the Food Safety and Standards Authority of India (FSSAI) is bringing a regulation on the subject. It has stipulated classification of recall, guidelines on recall and management of the recall process.

Classification of product recall

FSSAI is bringing out a regulation on recall of unsafe food. There are different classes of food recall (See Table 01) based on the impact on the health of the consumers. The draft regulations on food recall procedure have been issued to guide FBOs on how to carry out a food recall by facilitating the efficient, rapid identification and removal of unsafe food from the distribution chain and by informing consumers (where necessary) of the presence on the market of potentially hazardous food and ensuring that unsafe food are contained and destroyed or rendered safe. 

TABLE 01 Classes of Food Recall

Classification	Definition	Examples
Class I	This type of recall involves a health hazard where a reasonable probability exists that eating the food would cause serious, adverse health consequences or death.	Meat contaminated with L. monocytogenes in a ready-to-eat food product; E. coli O157:H7 in raw beef; allergens such as peanuts or eggs (not listed on the label).
Class II	This type of recall indicates a potential health hazard where a remote probability of adverse health consequences from eating the food exists, or if the resulting condition is temporary or medically reversible.	Presence of FD&C Yellow #5 dye in candy; presence of dry milk, a Class II allergen, as an ingredient in sausage without mention of the dry milk on the label.
Class III	This type of recall involves situations in which eating the food will not or is not likely to cause adverse health consequences.	A package containing fewer or lower weight products than shown on the package label or improperly labelled processed meat in which added water is not listed on the label as required by federal regulations.

Guidelines for Food Recall

This also provides guidelines to FBOs on how to establish a written recall plan for carrying out food recall in order to ensure the hygiene, safety and quality of food and to protect the health of consumers and to establish a follow-up action or post-recall report in order to ensure the effectiveness of the recall and prevent a repetition. All food businesses engaged in the wholesale supply, manufacture or importation of foods must have an up-to-date recall plan (See Table 02) except food retailer, unless they are also engaged in the wholesale supply, manufacture or importation of food, food businesses within the food service sector such as restaurants and takeaways are exempted to have recall plan unless they are running multi-outlet food business chains having integrated manufacturing and distribution network. However, such food businesses in the food service sector may be part of another business ‘recall, i.e. they may need to remove recalled stock from the shelves and return it to the manufacturer, importer or wholesaler. 

TABLE 02 Steps in the preparation of food recall plan

Sl.No.	Steps	Details of Activities
	Recall management team	Assemble the recall management team Identify the persons and assign the recall duties to them Small and tiny business operator may contain just one to two people to have above responsibility
	Notification	Notify the state food authority immediately Inform the consumer of the recall at the earliest possible moment in the form of press release, letter or paid advertisement in the media
	Identifying the food to be recalled	Identify any person whom they have supplied with the food Identify business and individuals to which his production has been supplied
	Product recovery	Store the recovered food separately and keep accurate records of the recovered food Correct / reprocess the food if it is fit for human consumption otherwise destroy in front of the state food authority
	Effective recall	Conduct effective check as a part of recall Amount of the food returned as a percentage of the amount of food which left the manufacturer while taking into account the retail turnover of that food
6.	Followup action	Provide the state food authority with an interim report as soon as recall is completed The circumstances, action taken, result of recall, method of disposal and preventive measures are to be reported
7	Recall termination	Retain complete documentation on the food recall for inspection request for termination The state food authority will terminate a recall after completing all recall activities

4. Food recall - Recent case

The Food and Drug Administration (FDA) of Maharashtra ordered recall of candy 'Mango Bite' because the manufacturer used buffered lactic acid (adulterant) in the confectionery which is not permitted. 

Frozen Tuna from India was recalled due to Salmonella Risk. The company in India that supplied the yellowfin tuna implicated in the multistate outbreak of Salmonella infections linked to sushi recalled frozen tuna strips because they, too, may be contaminated with Salmonella. The recalled tuna strips were shipped to four wholesalers in Georgia, Massachusetts, New Jersey and New York. In another similar incidence, infection of Salmonella had been reported from 24 states and the District of Columbia, according to the Centers for Disease Control and Prevention. The CDC says frozen yellowfin tuna, called Nakaochi Scrape, imported from India is the likely source of the outbreak. Many of those sickened reported eating sushi — in particular “spicy tuna sushi” — in the week before they became ill.

Sometime back there was tremendous controversy generated due to a Delhi-based research lab's report that all MNC and Indian company made soft drinks had pesticides contents far more than internationally accepted standards. The basic cause was contaminated water in India with pesticides used indiscriminately. But that could not give excuse to producers to pass off contaminated drinks. Though the storm had settled down, but not without long-term effects on credibility of soft drinks as safe products, these being banned in most of educational institutes’ canteens and lakhs of bottles were smashed by enraged protestors in various parts of the country. It necessitated relocation of some of the water bottling plants.

Conclusion

5.1 Food safety is a scientific discipline describing handling, preparation, and storage of food in ways that prevent food-borne illness. This includes a number of routines that should be followed to avoid potentially severe health hazards. The tracks within this line of thought are safety between industry and the market and then between the market and the consumer.

5.2 Food recall is an important link in ensuring food safety to the consumer backed by regulatory control on the food service operators. FSSAI has taken steps to bring out a regulation to have systematic approach to food recall which will go a long way in providing assurance to consumer.

References

1.CAC/RCP 1-1969 (Rev.4-2003), Recommended International Code of Practice- General Principles of Food Hygiene; incorporates Hazard Analysis and Critical Control Point (HACCP) system and guidelines for its application

2.ISO 22000:2005 Food Safety Management Systems- Requirements for any organisation in the food chain

3.The Food Safety and Standards Act, 2006, Ministry Health and Family Welfare, Government of India

(The writer is MD, Quality Care Services Pvt. Ltd, New Delhi, and food safety expert, UNIDO, Vienna. He can be contacted at qualitycare1995@gmail.com)