Templates and records · BRCGS · Clause 3.11
BRCGS incident management and product recall
A tested procedure for deciding on and carrying out a recall, with the added obligation to notify the certification body when one actually happens.
In one sentence
BRCGS incident management and product recall documents the procedure for deciding on and carrying out withdrawals and recalls — team, emergency contacts, criteria, communication — its testing at least once a year and, in a real recall, notification of the certification body within three working days of the decision, as clause 3.11 requires.
- Where the standard requires it
- BRCGS · Clause 3.11 Clause references follow the numbering of BRCGS Food Safety Issue 9. If your audit is already against a later issue, check the correspondence on brcgs.com.
- Type of information
- Mandatory record Procedure and records to be retained (3.11)
- Who fills it in
- Incident management team With representatives of senior management, quality, sales and logistics
- When
- Tested at least once a year And at every real incident, with notification to the certification body
- How long it is kept
- Shelf life plus 12 months, at least BRCGS requires a retention period to be set taking into account legislation, the customer and the product's shelf life, and as a minimum records must be kept for the shelf life plus twelve months (3.3).
What the standard requires
What BRCGS demands and what it leaves to your judgement
BRCGS requires procedures for managing incidents — disruption of supply, natural disasters, contamination, sabotage — and product withdrawals or recalls. The procedure identifies the key staff on the incident management team, includes up-to-date contacts for customers, suppliers, authorities and the certification body, and sets out how information will be given.
The recall procedure is tested at least once a year, in a way that checks it works in practice, and the results, including timings and lessons learned, are recorded.
If there is a real recall or a serious food safety incident, the body that issued the certificate must be notified within three working days of the decision. The legal obligation to withdraw a food and inform the authority is set out in Article 19 of Regulation (EC) 178/2002.
Structure
Fields the template should include
- Incident team with roles and deputies
- Emergency contacts and date they were last checked
- Scenario or incident, batch and date
- Start, decision and close times
- Communications: customers, authority, certification body
- Quantity located and recovered
- Lessons learned and actions
- Review of the procedure
Example
Example: annual recall test at a fictitious sauce plant
Company, people and figures are fictitious: the example only shows what a properly completed record looks like.
| Field | Content |
|---|---|
| Scenario | Mayonnaise 450 g · batch MY-26-140 · possible glass contamination at packing |
| Team | Site director, quality, sales, logistics · quality deputy activated due to holidays |
| Decision | 10:05, 35 minutes after the alert |
| Customers | 5 distributors contacted before 12:30 |
| Simulated recovery | 96% of the batch located in customer warehouses |
| Certification body | The contact and the three-working-day notification deadline are checked |
| Lesson | One distributor's out-of-hours phone did not answer · a second contact is requested |
At the audit
Mistakes auditors commonly flag
- Emergency contacts that nobody has checked during the year.
- The procedure provides no deputies for the incident team.
- The test stops at a traceability query.
- Real recalls not notified to the certification body.
- Lessons learned that do not change the procedure.
In Kimobox
How this record is kept in Kimobox
- 1The mock recall returns the affected batches and customers in minutes.
- 2The exercise is recorded with its timings, communications and lessons learned.
- 3Alerts to the incident team are sent as push notifications with read receipts.
- 4Periodic checking of contacts is scheduled as a task with a reminder.
Frequently asked questions
What people ask us before getting started
Must the certification body be notified of a recall?
Yes, of a real recall or a serious food safety incident, within three working days of the decision. In an exercise nothing is notified, but it is worth checking that the contact is correct.
Which incidents does the procedure cover?
Besides recalls, any situation that could affect the safety, legality or quality of the product: water or power cuts, fires, contamination, sabotage or failures by critical suppliers.
Does a real recall count as the annual test?
It is usually accepted if it was handled using the procedure and is documented with its timings and lessons. If there was none, the test is carried out with a simulated scenario.
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Sources
Where each figure comes from
References to the official text in force. If a standard is revised, this page is updated and the review date says so.
- BRCGS Global Standard for Food Safety, Issue 9 BRCGS · Published August 2022
- Regulation (EC) No 178/2002 laying down the general principles and requirements of food law (Articles 18 and 19) EUR-Lex · 28 January 2002