R.

How to Conduct a Mock Recall — An Example

NOTE: The Appendices were originally developed for Canadian

NOTE: operations, and provide examples only, based on Canadian and
international resources. If your operation is outside of Canada, the
following information may be relevant to you. It is recommended that
you check whether country-specific requirements or guidance are
available instead.

Periodic mock recalls should be carried out at least annually to evaluate the product recall program. All
information obtained during the Mock recall is documented on the Mock Recall Log*. Mock recalls are
used to determine whether the recall procedure is capable of identifying and quickly controlling a given
lot of potentially affected product and reconciling the quantities produced, quantities in inventory, and
quantities distributed. Mock recalls are used to test all steps of the recall procedure, including
identifying where the product went. A mock recall will identify potential problems and allow personnel to
become familiar with recall procedures. Use the Mock Recall Log to document all corrective actions
and deficiencies identified. The steps below and attached sample Mock Recall Log can help guide
you through the mock recall process:

1. Identify and write down the mock recall scenario. Make up something fairly realistic and be
specific about the customer or supplier (where the recall originated) and the specific product to
be recalled. Example: We determined that when Bravo 500 was sprayed on our cabbage
fields on July 5`" (9 days ago) the third party applicator also accidentally sprayed two of our
spinach fields (fields S9 and S10). Since Bravo 500 is not registered for spinach we need to
recall any spinach that has been harvested and distributed from those two fields since we
started harvesting on July 12`h. Example: On August first we received notification from CFIA
that their surveillance sampling program found a positive result for Salmonella Poona on a roma
tomato. The roma tomato sample was taken from a distribution warehouse and had the
following pack ID: 225AR. We need to find out whose tomatoes are in the affected pack ID's,
whether tomatoes from the affected product from the identified delivery date are in any other
Pack ID's and where all potentially affected product went.
2. Identify and record who will be involved in the mock recall. For example: John Smith, recall
coordinator, will be in charge of the mock recall with help from Jane Brown the field supervisor
and Jay White the packing house supervisor. All members of the recall team should participate
in a mock recall.
3. Record the time when you start the exercise.
4. Once the particular affected lot is chosen for the scenario, trace the product forward to the
customers and, if applicable, back to the field or the operation. Find out how much of that
particular lot or pack ID was produced, where it came from and where it was sent. Collect and
gather copies of records with the supporting data such as: transportation records (Form O),
packing and/or harvesting records (Forms P and Q), agronomic inputs (Forms H1 and H2). The
mock recall file also should include the name, address and telephone number of customers
and/or suppliers for the lot tested.
5. Keep track of everyone within your organization you contacted to collect each piece of
information or where it is stared (e.g. which binder or file in which office). If records are kept
electronically keep track of how reports were generated (what is the report called in the software
system?) so that it is easy to repeat the process if a real recall occurs.
6. Make copies of the applicable forms from your Recall Program and record how much product
was found and where it was found (e.g. 4 skids with each with 50 masters sent to Sobeys on
Aug 7).
7. It is recommended that your customers are contacted to ensure that their contact information is
accurate etc. At the beginning of the call you would let them know that it is a mock
recall/simulation. Write down which customers you would call to get the product back and write
down a mock entry. Include company, contact person and phone numbers.
VERSION 7.1 73 CanadaGAP Food Safety Manual Appendices
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 8. Record the time when you finished the exercise.

9. Meet with your recall team to discuss the mock recall, and how things could be improved.
Record these findings and create an action plan for continuous improvements. Other topics to
discuss during the final review meeting could include what you would do to dispose of the
product, media policy, communication strategy, etc.

*A sample Mock Recall Log is included on the following page

Ways to make your mock recall more effective and a better learning experience:

1. Timing and frequency: be unpredictable (do not tell staff ahead of time) and schedule the mock
recall for busy or inconvenient times. This can give you the most realistic idea of how effective
your recall process is.
2. Be Realistic: the more realistic the scenario, the better prepared you will be if something actually
happens. Start with a fairly easy scenario, then in subsequent years try and make the scenario
more complex.
3. Be comprehensive: include all departments and test all aspects of your recall plan. If possible
involve other supply chain partners (e.g. if you pack product involve the individual operations.)

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 Mock Recall Loq
Company Name: August's Harvest Date: July 17th 2019
START Time: 4PM

Who participated in the Mock Recall? Matt &Tamara Comments

Name Position Mock Recall

Responsibilities/Duties
Matt Ham Project Manager Coordinator
Tamara Hunt Manager, Admin Services Recall Assistance
Reicza Ham General Manager Overseeing
Andrew Russel Production Manager Re-Ordering

Mock Recall Scenario Comments

- Specific product to be recalled
- Customers/suppliers involved
Customers/Suppliers Involved: Loblaws -Atlas (X-Dock) / Us: August's Harvest (August's Harvest) Lot#: 374R
Freight: Ippolito Transportation
Invoice# 6900 -Mixed Pearl Onions
Bleach spilled on Red Pearls (Lot# 374) at Men's Farming before getting shipped to us. Men's -Case (18 x 250gm) Hymes
Farming doesn't notify us until product is shipped out of our production area by Ippolito
Transportation PO 1248 and Invoice# 6900 is on its way to the X-Dock.

(Loblaws does not receive them!) Total Recalled: 40 Cases of Red

Pearls

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 Contacting Customers/Suppliers Comments
- Identify who/where product was shipped to and who/where it came. from
Who wouM you call to get the products back?

Lot# 374 has been contaminated

Company Contact Number prior to receiving it at August's
(Supplier) Men's Farming Domestic Team Harvest but not communicated
(519) 842-7701 until Invoice# 6900 is on route to
(Ressler) August's Harvest Manager, Admin Services (519) 393-5550 the Loblaws X-Dock.

(Transport)IppolitoTransportation ~~~-~*o~~.a.~..~o,,,,a~,a.~m.~.,.~ (g05) 639-1174 Ex. 3110

(Customer) Loblaws X-dock Domestic Team (844) 269-3923

List of applicable records collected/gathered .Where is this information Comments
(Attach all relevant forms). . stored?
Form O -Transporting Product -cap Binder zOts
Form Q -Gap Binder 2019

(AHI's) Bill Of Ladings &Shipper Sheet -ouickbooks

(MF'S) Bill Of Ladings &Bills

(Lot #'s) Class List

Finish Time: 6PM

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Identify gaps in your Recall Program and create action plan for improvement

Gap/Flaws identified during recall:

- Contact information not obvious or easy to find

Action Plan:

-Ensuring all paperwork is being inputted into the correct places (Ex. ~uickbooks &Gap Forms)
-Ensuring all contact information is being kept up to date.

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S Recall Program
NOTE: The Appendices were originally developed for Canadian
NOTE: operations, and provide examples only, based on Canadian and
international resources. If your operation is outside of Canada, the
following information may be relevant to you. It is recommended that
you check whether country-specific requirements or guidance are
available instead.
1. Introduction
Everyone involved in the produce supply chain must do their part to ensure that the fruits and
vegetables they offer are safe for consumers. Although most fresh fruits and vegetables retain a short
shelf life, it is important to establish a recall program within an operation. If a product has been
implicated as the source of a problem, accurate information must be readily and easily accessible to aid
in the recall process.
Users following any of the CanadaGAP manuals will have a traceability system in place whereby
packaging materials have a pack ID and have been identified (name/address). However, if a problem
were to occur, the person responsible requires a means to recall product, thus the need for a recall
program.
2. Program Components
An effective program includes, as a minimum, the following elements:
1. Names) and contact information of the recall coordinators) and recall team.
2. Written step-by-step procedures to be followed during a recall:
• Record the reason for the recall and the health risk (Form 1 —Recall Information).
• Halt distribution of the product and isolate the quantities still within the operation.
• Identify the product and determine the quantities involved (Form 2 —Product Information).
• Identify who needs to be contacted (Form 3 —Contact Information).
• Communicate with the parties concerned (Forms 4A and 4B —Recall Notifications).
• Recall the product (Form 5 —Product Retrieval).
• Properly dispose of all contaminated product.
• Determine preventative plans (Form 6 —Follow-Up Plan).
It is very important to keep accurate and complete records during the recall process. A recall is
terminated when both CFIA and the recalling person responsible agree that the recalled product
has been effectively removed from the supply chain and that the proper disposition and/or
corrective actions) have been completed.

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 FORM 1
RECALL INFORMATION

Recall Coordinator:
Mathew Ham &Tamara Hunt

Contact Information: (519) 393-5550

Date/Time: July 17, 2019 @ 6PM

Reason for Recall: Describe the reason for the recall (biological, chemical or physical contamination)
and how the product deficiency was discovered.

- Received a call from Men's Farming letting us know that a bottle of bleach left on the grading
line to clean the machinery was discovered tipped over, spilling on an area where they had
been holding the red pearl onions. They didn't communicate measures until the next day, after
which a shipment had left August's Harvest on its way to X-Docks.

- Chemical Contamination.

- Had the product reached the consumer and we are unsure of how much bleach has been
contaminated the product recall would be classified CLASS 1.

-Considering the product hasn't reached the consumer, we are classifying this recall as Class
3.

Hazard Assessment: The CFIA will assess the health risk and rank according to the following
classifications:

Class 1: A reasonable possibility of serious adverse health consequences.

Class 2: A remote possibility of serious adverse health consequences.

A possibility of temporary adverse health consequences.

Class 3: A low possibility of adverse health consequences.

* Go to the following CFIA website for complete definitions: http://inspection.gc.ca/food/safe-food-

production-systems/food-recall-and-emergency-response/food-
manual/eng/1378402475724/1378403080658?chap=l2

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 FORM 2

PRODUCT INFORMATION
Shipped To
Lot Number/ Lot Quantity Shipped and
Product Date Quantity Lek
CodelDate Quantity Name/Location Requiring Recovery
Shipped On-Farts

Red Pearl Onions 374R 9451bs Lob~aws -Atlas 07/17/19 812.84 All 40 cases recovered

TOTAL=qO Cases of Red Pearl Onions

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 FORM 3

CONTACT INFORMATION
Canadian Food Inspection Agency (CFIA)

When there is a potential food recall, the CFIA Area/Regional Recall Coordinators/Contacts must be
notified. They will help with the recall process and will determine the recall class and course of action.

Website: www.inspection.gc.ca 1-800-442-2342

Nova Scotia, Newfoundland and Labrador,
Prince Edward Island &New Brunswick 506-381-7683
Quebec 866-806-4115
Ontario 416-665-5049
Manitoba 204-797-4501
Saskatchewan 306-529-0671
Alberta 587-230-2518
British Columbia 604-292-5780

Who needs to be contacted? (Person responsible keeps a complete list of customer contacts
available)

Who? (✓ all applicable) Why?

CFIA Contact ✓ Contact will help with recall process
Person Who Produced the
Product ~ Men's Farming - contacts AHI (notification of contamination)
Provincial/Territorial
Association/Organization
Person Who Packed the August's Harvest Production Team -Notify to redo order with new
PfOdUCt ~ product for Loblaws to ship out on next shipment.
Wholesaler

Broker

Certification Body
GAP- Notification of recall
Retailer / Loblaws Allas - Product has yet to be delivered -Contacted notifying order for red
v pearls has been backordered
Foodservice

Consumer

Other (e.g., CanadaGAP,

~/ Ippolito Transportation -Notify transportation to
law enforcement, etc.) arrange return of contaminated product

VERSION 7.1 $5 CanadaGAP Food Safety Manual Appendices

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 FORM 4A

RECALL NOTIFICATION —Via Phone

The following information is to aid you when contacting people to recall your product. Fill out one sheet
for each group contacted.

This is Matthew Ham . I am calling from AUgUSt'S H8V2St

Name of Recall Coordinator 71,E 71,E your operation's name
to notify you that all product 374 on 9 needs to be
lot # date/time
returned
returned, destroyed, modified, etc.

I have the following questions to ask you about this recall:

1. Who do I speak to about a recall and what is their contact information?

Julie Dinsdale (Ippolito Transportation)
Contact (name):

Phone Number: 1 (905) 639-1174 eX 3110

Fax Number: (905) 631-7711
Title: Domestic GTA Logistics
2. Do you have any of the products) being recalled? (If no, terminate questioning)
X YES NO

If the answer to question #2 is YES, the product must be destroyed

returned, destroyed, modified, etc.

3. The returned &remaining of this product will be dealt with by

return, destruction, modification, etc.

Compostable Waste Disposal

action intended

4. Have you received any reports of illness or injury related to this product?

YES X NO

If yes, please provide details.

Thank you for your time.

Confirmation Signature: CAI~n.-~~ ~J Date: ~ I I~ I I

VERSION 7.7 g] CanadaGAP Food Safety Manual Appendices

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 FORM 5
PRODUCT RETRIEVAL
Ouantiry Shipped Total Quantity
and Requldng Datel Time Quantlry Quantity Actlon Taken and Description Recovered
(from Form Person
Recovery Contacted Recovered or Remaining Wkh (e.g., picked up, returned, (ahould be tha
4) Deavoyea COMact destroyed, etc.) same as
(from Form 2)
columnat(
40 roses Mixed Pearls ]/1]/194:45pm Julie Dinsdale 40 Cases Zero Destroyed 40 Cases

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 FORM 6

FOLLOW-UP PLAN

1. Why was there a recall (i.e., what was the source of the problem)?
Bleach left to clean equipment was accidentally spilled onto product. Employee responsible

for cleaning did not notify Men's Farming regarding the situation until after AHI had received product and

shipped the first shipment with the the contaminated product. 40 cases of red peal onions were

contaminated as a result.

2. What corrective actions) was/were taken? (List and describe)

1. Following up with all contacts to ensure the product doesn't make its way to our customers

2. Men's fired empoloyee responsible for not notifying management soon enough.
3. Employee responsible (Andrew Russell) was reprimanded for not having more
thoroughly inspected the product for smells, as the chlorine may have been detectable by smell.

3. What ongoing procedures did you put in place to prevent recurrence of the problem?
Created line on our PO's for vendor/supplier to sign 8 return stating [hey have assessed and inspected product, production site &

cargo area of transportation for quality and contamination issues (See included example PO). Reminded employees that in receiving

product they are responsible for ensuring that there are no quality issues with it. This includes issues that might only be

detectable by smell or discoloration. If there is any doubt about the quality of a product management is to be notified as soon as possible.

4. Identify the persons) responsible for ensuring the above actions and procedures are monitored and
implemented.
Our suppliers -Men's Farming
Production Crew- including Chris Huggins, Susan Peters, and Susanna Janzen.
Production Manager -Andrew Russell
Matthew Ham -Project Manager &Tamara Hunt -Manager, Admin Services

Confirmation Signature: ~G~.w-~ t'~"V~~~ Date: I I ~~ I l

VERSION 7.1 g1 CanadaGAP Food Safety Manual Appendices

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Other Communications

Yes No
Press Release x
Public Notification

x
Other (specify): x

VERSION 7.1 $6 CanadaGAP Food Safety Manual Appendices

2018
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426W 11/22/2019 ❑ 0 Produc White Pearl Onions AHi 2 1000 Ibs Bin 1,735.00 12/2/2019 Andrew Rcvd Good 1352 '9145
4268 11/22/2019 ❑ Produc Red Pearl Onions AHI 2 1000 Ibs Bin 1,744.00'. 12/2/2019 Andrew Rcvd Gaod 1352 9145
4266 11/22/2019 ❑ 0 Produc Gold Pearl Onions AHI 4 lOW Ibs Bin 3,697.00. 12(2/2019 Andrew Rcvd Good 1352 9145
4305 12/10/2019 ❑ Produc Shallots AHI 10 1W0 Ibs Bin iQ062.W 12j16(2019 Andrew RcvdGood 1362 9173
4306 12/10/2019 ❑ Produc Gold Pearl Onio~u AHI 2 SOW Ibs Bin 4,040.00 12/16/2019. Andrew Rcvd Good 1362 9173
43017 12/10/2019. ❑ Produc White Pearl Onions AHI '2 lOW Ibs Bin 1,680.W 12/16/2019 Andrew Rcvd Good 1362 9173
4308 12/10(2019 ❑ 0 Produc Red Pearl Onions AHi 2 lOW 16s Bin 2,240.00 12(16(2019 Andrew Rcvd Good 1362 19173
4345 12/26/2019 0 ❑ Produc Shallots AH1 10 SOW Ihs Bin 9,825.W. 12/30/2019' Andrew Rcvd Good 1373 .9188
4340 12/26/2019 © ❑ Produc Cippolims AHI 2 SOW Ibs Bin 1,981.00. 12/30(2019. Andrew 'Rord Good 1373 9188 N ~~~` ~
4355 1/2/2020 0 ❑ Produc Shallots AHI 5 10W Ibs Bin 6,235.W 1/7/2020 Andrew Rcvd Good 1377 9196
435W 1/2/2020 © ❑ Produc White Pearl Onions AHI 4 lOW Ibs Bin 1,325.W' 1/7i2020Andrew Rctd Good 1377 . 9196
435fl 1/2/2020 © ❑ Produc Red Pead Onions AHI 4 lOW Ibs Bin 4,040.00 1/7(202(} Andrew Rcvd Good 1377 .9196
4356 1/2/2020 © ❑ Produc Gold Pearl Onions AHI 1 lOW Ibs Bin 1,289.W 1(7/2020 Andrew Rcvd Good 1377 9196