Withdrawal, Recall—But Not from the Food Safety Path!

Two Concepts Confused (Withdrawal, Recall) in Food Safety Management System Applications….

If news reports appeared on newspapers, television, or the internet stating, "Consumers who bought 'Brand X' chocolate product or 'Brand Y' bottled water should not consume the relevant products due to the possibility of foreign material and/or plastic contamination, and consumers holding products with lot number 123... can return these items to the manufacturer," how many of us would still choose products from these brands when we go to the market?

When this question is posed during food safety training sessions without first explaining the necessity of withdrawal and recall and the standard requirements, the typical answer from participants is: "Of course, I would buy a different brand or product."

After explaining that it is a requirement, based on standards, for a manufacturer to collect a product from the market, if necessary, when they detect a flaw that could affect human health;

We then ask, "What if the firm you chose instead noticed glass contamination in its product but, thinking about its reputation and fearing consumer reaction, did not withdraw the product from the market or collect it from the store? What if you noticed this situation while consuming the product?" Suddenly, the answer changes.

In our country, a specific guideline for the food sector regarding legal regulations on this topic has not yet been established. While a global company may implement a withdrawal-recall action when, for example, glass contamination is detected in a product in other countries, food safety system-implementing firms in Turkey have not yet been seen to carry out such publicly reported recalls.

The reaction consumers have when reading food labels sometimes leads them to react negatively to firms that provide accurate declarations in terms of food safety. And if implemented, the same perception is likely to form against companies that withdraw/recall their defective products from the market. Therefore, consumers need to be educated on the subjects of food safety, withdrawal, and recall.

Clarification is also needed regarding the topic of withdrawal and recall, two concepts often confused in the implementation of food safety standards. These terms, which relate to recalling or collecting a product that has been sold from the market, have mostly resonated in Turkey through applications in the automotive sector. Yet, similar applications should be expected to develop and be implemented in our country in the pharmaceutical, cosmetic, food, and other sectors directly related to human health.

Although the concepts of withdrawal and recall are defined in legal regulations for these sectors, doubts persist regarding their feasibility or correct implementation. Especially as seen in recent examples of public disclosure of market surveillance results, often featured in the media, it is noticeable that the Turkish public is not yet educated on the fact that any product being substandard necessitates its withdrawal or recall from the market as a natural process.

The updated regulation clearly explains the withdrawal-recall process for companies as follows: Article 40 of the "REGULATION ON OFFICIAL CONTROLS OF FOOD AND FEED," published in the Official Gazette on December 17, 2011, under number 28145, states: "(2) If the food and feed business operator assesses or has reasonable grounds to believe that a product they have produced, processed, imported, sold, or distributed does not comply with food and feed safety requirements, they must immediately initiate the necessary procedures for the collection of the product, starting from the stage it left their control, and must inform the Provincial/District Directorate of the Ministry concerned. When the product needs to be collected, the food and feed business operator must inform the consumer or user accurately and effectively about the reason for the collection, and where necessary, if the measures taken to protect human and animal health are insufficient, they must call upon the consumer or user to return the product."

Furthermore, concerning the procedures to be implemented by the Ministry during official controls, Article 8—under Transparency and Confidentiality—states:

"(1) The Ministry shall ensure that activities related to official controls are carried out with a high level of transparency. The Ministry shall make the following information public by announcing it on the Ministry's official website, provided that the provisions set forth in the sixth paragraph of Article 31 of the Law are observed: Approved and registered establishments, establishments whose approval has been suspended, establishments whose approval has been cancelled, registered establishments whose activity has been suspended by the Ministry, the name of the firm that produced/imported the food or feed confirmed by laboratory results to be adulterated or misrepresented, the product name, brand, lot and/or serial number, the name of the firm that produced and/or sold food that has deteriorated or been altered in a way that endangers human life and health, the product name, brand, lot and/or serial number. The information in the fourth paragraph of Article 26 of the Law shall be publicly announced as soon as possible.

(2) The Ministry may implement practices that encourage food safety in workplaces found to be operating in compliance with the relevant legislation as a result of official controls, and may share this information with the public. The procedures and principles regarding these practices shall be determined by the Ministry within the scope of this Regulation."

The concept of withdrawal is the process of requesting and collecting the sold product back from the points of sale. If the unsafe product cannot be retrieved in the quantity distributed and there are situations where it has reached the consumer, the producer may need to recall the product from the consumer. This necessity is related to the harm the product may cause the consumer. Product withdrawal can sometimes be due to microbiological, chemical, or physical contamination. In terms of its effect on human health, the withdrawal-recall process can be carried out at various levels, and the consumer must be informed about the seriousness of the issue in detail the moment it is implemented.

We all know how these examples are experienced in Turkey. On the other hand, in a recall example that occurred in Dubai in March 2012, the newspaper/internet headline started with "The Ministry calls on consumers not to panic about the recall issued for water." Following this, the news explained the seriousness of the problem in which specific brand and lot number, and what consumers should do in this situation. The most striking point in the news, which included analysis results from different authorities regarding bromate, a chemical known to cause cancer, found at unacceptable levels in Brand X water, was this: The Ministry shared with the consumer, right at the beginning of the sentence, that there were no issues with the other batches of the relevant brand.

FDERD- RECALL- WITHDRAWAL

Risk communication should be correctly established between the producer and the consumer, guided by legal authorities. The Alo174 Food Line is a good step taken in this regard. Additionally, producers must also be enabled to reach the consumer through correct channels. The "rapid alert system" mentioned in the regulation and functioning very well in international trade worldwide must be established in Turkey as soon as possible. While the disclosure of official control results declares adulteration/misrepresentation (and "frauds" as the media calls them), it is necessary to allow and enable the producer to fulfill their responsibility for withdrawal-recall and to establish communication with the consumer regarding products found to be non-compliant during market surveillance. Otherwise, it will be "beating the messenger" without weighing the impact and extent of the threat to human health, and thus, food safety practices cannot work effectively for both the producer and the consumer, nor can correct perceptions be formed. It must be remembered that the primary aim of no investor who establishes large factories, provides employment to thousands of workers, and offers us the food that comes to our tables every day is to "play with people's health." The problem is not so much making mistakes as it is refusing to admit them.

Nonconformity or unconscious practices can happen in food production; the important thing is to protect human life without covering up the issue when a problem arises.

Fatma İnceoğlu - 7.12.2012