How we decide to recall a food product
When there is reason to believe that food is unsafe or does not follow federal regulations, the Canadian Food Inspection Agency (CFIA) initiates a 5 step process to investigate and determine if a food recall is necessary.
The Canadian food supply is one of the safest in the world. However, no food safety system can guarantee zero risk. At any point in the production system, food can become contaminated with bacteria, viruses, parasites, chemicals, undeclared allergens or material such as glass or metal fragments.
Step 1: Trigger
Several triggers can start a food safety investigation, which could lead to a food recall. Such triggers include, but are not limited to:
- Suspected or confirmed foodborne illness outbreak
- Food test result
- Food inspection finding
- Complaints from consumers, industry, other government departments or associations
- Company-initiated recall
- Recall in another country
- CFIA audit/assessment/evaluation findings
- Referrals from other branches within the CFIA
- Referrals from other federal/provincial/territorial, municipal and international government departments or food safety organizations (for example, the International Food Safety Authorities Network) law enforcement or the medical community
- Traditional or social media
Step 2: Food safety investigation
Food safety investigations are complex and involve several essential steps to determine if a food recall is required and what food to recall. When dealing with potentially unsafe food, the CFIA acts as quickly as possible to collect information and make decisions. Food safety investigations are carried out by a variety of experts at the CFIA, including inspection staff, and will continue until complete and sufficient information is gathered to develop a strategy to mitigate the risk.
- To identify which food may be contaminated and with what hazard
- To determine if there is a health risk
- To determine how far in the food distribution system (for example, to the manufacturer, importer, distributor, retailer or consumer level) potentially unsafe food has been distributed
- To determine if a recall and/or other action (such as, detention of food or suspension of an operating license) is needed to protect consumers
- To identify the root cause of the problem, if possible
Traceback activities help determine where the food originated, while traceforward activities help determine where the food was distributed. Both are routinely done during a food safety investigation.
- These activities are used to follow the food through the distribution system to identify where the problem occurred, what food should be recalled and to what level of distribution
- These activities can become complex when food is sold to other companies that repackage or use the food as an ingredient to make other food products
Once potentially unsafe food is traced back to a production or processing facility, or to an importer, CFIA inspectors immediately conduct an on-site visit and may:
- observe processing or production practices
- review documented procedures
- observe/inspect equipment and establishment conditions
- obtain production and distribution records
- identify if other food is unsafe or potentially unsafe
- gather information on unsafe or potentially unsafe food such as the brand name, product code, UPC, label, package, expiry/best before date
- verify accuracy and completeness of information
- collect food samples and send for laboratory testing
- verify the possible root cause of the problem
- determine when the problem started and ended
- verify any corrective actions the company has taken
What inspectors observe, collect and document on-site is a critical piece of the food safety investigation.
Step 3: Risk assessment
The findings of the food safety investigation may indicate that a food represents a potential health risk which needs to be assessed in order to make a decision to mitigate the risk.
When a hazard is identified in a food in distribution, a technical risk assessment can be completed internally by CFIA experts or a formal request for a health risk assessment can be submitted to Health Canada. The purpose of these assessments is to determine the level of risk a specific food presents to Canadians by evaluating the likelihood of exposure to the food and the potential severity of the illness or injury.
Assessing the risk also determines whether actions are required and which ones would be the most appropriate to mitigate the risk. When it is known that a food recall will need to be considered as one of the actions, assessing the risk associated with the food in question becomes an essential step.
Step 4: Recall process
A food recall is the removal of a food from further sale or use, or the correction of its label, at any point in the supply chain as a risk mitigation action. It is the responsibility of industry to effectively remove the recalled food from the marketplace.
Based on the risk assessment, the CFIA determines the most appropriate action to mitigate the risk, including whether or not to request a food recall.
If a recall is necessary, the CFIA also assigns a class to the recall, as follows:
- Class I: There is a high risk that consuming the food may lead to serious health problems or death
- Class II: There is a moderate risk that consuming the food may lead to short-term or non-life threatening health problems
- Class III: There is a low risk that consuming the food may result in any undesirable health problems. This class also includes food that do not pose a health risk, but that do not comply with legislation
Most recalls in Canada are voluntary meaning that they are conducted by the responsible company with oversight from the CFIA. If a company is unable or refuses to conduct a voluntary food recall, the Minister of Health has the power to order a mandatory recall for all food that poses a health risk.
When a recall is the appropriate action to take, the CFIA requests that the company (now referred to as the recalling firm) initiate a voluntary recall.
The recalling firm is responsible for contacting all of its clients (for example, distributors or retailers) that have or may have received the recalled food.
The CFIA's role is to inform the public, oversee implementation of the recall, provide guidance and verify that industry has effectively removed recalled food from the marketplace.
Informing the public
The CFIA issues public warnings through the media to notify the public about high risk recalls and allergen recalls. Informing the public about high risk recalls is critical as consumers may have recalled food in their homes.
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Balancing the need to have reliable information with the need to inform the public as soon as possible means that the CFIA sometimes issues public warnings while food safety investigations are ongoing. As the CFIA identifies additional recalled food, it will issue additional public warnings in order keep consumers informed of potential risk.
If food has been recalled, it is the responsibility of industry to remove it from the marketplace immediately.
The CFIA conducts effectiveness checks to verify that unsafe food has been effectively removed from the marketplace. If the recall is determined to be ineffective, the CFIA will request that the recalling firm redo the recall or will recommend that the Minister of Health issue a mandatory recall, as appropriate.
If a recalling firm is unwilling to remove the food from sale and appropriately dispose of it, the CFIA may seize and detain the food.
The CFIA will also verify that the recalling firm has handled the recalled food correctly. For example, if the recalling firm chooses to dispose of the recalled food in a landfill, CFIA experts may oversee the transportation of the food to ensure appropriate disposal.
Step 5: Follow-up
Once the recall is complete and the recalled food has been removed from the marketplace, the CFIA continues to work with the processor, manufacturer or importer to ensure that any problems that led to the recall are resolved.
Companies are responsible to prevent reoccurrence of the incident by implementing corrective actions and ensuring the disposition of the unsafe food. CFIA inspection staff will monitor the company to ensure the corrective actions are implemented effectively. The CFIA may also review standards and policies to determine whether revisions are necessary, as needed.
The CFIA sometimes works with industry sectors or foreign countries to address trends that go beyond a particular company, sector or recall.
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