2.6 Product Traceability Recall and Crisis Management

2.6.1.1 The methods and responsibility for identifying products during all stages of storage shall be documented and implemented. The product identification system shall be implemented to ensure:

• i. Proper stock rotation;

• ii. Accurate location of product.

2.6.1.2

• Records of product receipt and use and product dispatch and destination shall be maintained.

2.6.2.1 The responsibility and methods used to trace product shall be documented and implemented to ensure:

• i. Traceability of food products to the customer (one step forward);

• ii. Traceability of product to the supplier or manufacturing supplier with date of receipt (one step back);

• iii. Traceability is maintained where product is recouped;

• iv. The effectiveness of the product trace system is reviewed at least annually as part of the product recall and withdrawal review (refer to 2.6.3.2).

2.6.3.1 The responsibility and methods used to withdraw or recall products shall be documented and implemented. The procedure shall:

• i. Identify those responsible for initiating, managing, and investigating a product withdrawal or recall;

• ii. Describe the management procedures to be implemented including sources of legal, regulatory and expert advice, and essential traceability information;

• iii. Outline a communication plan to inform employees, customers, consumers, authorities, and other essential bodies in a timely manner appropriate about the nature of the incident;

• iv. Ensure that SQFI, the certification body, and the appropriate regulatory authority are listed as essential organizations and notified in instances of a food safety incident of a public nature or product recall for any reason.

2.6.3.2 The product withdrawal and recall system shall be reviewed, tested, and verified as effective at least annually. Testing shall include incoming materials (one back), inhouse identification and isolation/quarantine, and where the product is shipped to (one forward).

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2.6.3.3 Records shall be maintained of withdrawal and recall tests, root cause investigations into actual withdrawals and recalls, and applied corrective and preventative actions.

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2.6.3.4 SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety event that has been initiated by the site requires public notification. SQFI shall be notified at foodsafetycrisis@sqfi.com.

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2.6.4.1 A crisis management plan based on the understanding of known potential dangers (e.g., flood, drought, fire, tsunami, or other severe weather event, warfare or civil unrest, computer outage, pandemic, loss of electricity or refrigeration, ammonia leak, labor strike) that can impact the site’s ability to deliver safe food, shall be documented by senior management outlining the methods and responsibility the site shall implement to cope with such a business crisis. The crisis management plan shall incl

• A senior manager responsible for decision making, oversight, and initiating actions arising from a crisis management incident;

• The nomination and training of a crisis management team;

• The controls implemented to ensure a response does not compromise product safety;

• The measures to isolate and identify product affected by a response to a crisis;

• The measures taken to verify the acceptability of food product prior to release;

• The preparation and maintenance of a current crisis alert contact list, including supply chain customers;

• Sources of legal and expert advice;

• The responsibility for internal communications and communicating with authorities, external organizations, and media.

2.6.4.2 The crisis management plan shall be reviewed, tested, and verified at least annually with gaps and appropriate corrective actions documented. Records of reviews of the crisis management plan shall be maintained.

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