Shipping - 7.1 Traceability and recall

Without a full chain traceability system, product recalls can be slowed down and products posing a food safety hazard may remain in the food chain.

Good agricultural practice applies to all farms.

What needs to be done

Identify and record all products and inputs throughout the production process so that they can be traced backward to the original supplier and forward to the next step in the supply chain as part of a full-chain traceability system.

How to do it

Identify the premises

Consider including the following information for premises identification:

• Geographical coordinates or legal land description, for example a parcel identification number (PID)
• Civic address of premises
• Commodities produced
• Owner information (name, phone number)
• Contact information (name, phone number)
• Facility type (farm, auction, feedlot)

Identify the products:

• Track inputs and incoming materials as they are received onto the farm and used during production
• Maintain records of input/product inventories, processes such as animal health product use, pesticide use, nutrient application; and harvest information
• Record-keeping requirements are listed in each appropriate good agricultural practice in this guide
• Identify all food, livestock and poultry or label them with information that accurately represents the product

Record movement:

• Make sure you can share information on food, livestock and poultry with the next level in the food supply chain where requested.
• Link identification of outputs to the premises identification where they were produced.

Preparing for a recall:

• Identify and record contact information for local regulatory authorities, veterinarians, suppliers/buyers, commodity organizations and emergency personnel in case of recall.
• Be prepared to give the necessary information on hand to give to authorities in the event of a recall.

Responding to a recall

When a problem has been identified within your operation and a recall needs to be initiated, one of your first steps will be to notify the Canadian Food Inspection Agency (CFIA) immediately. When you call, you will need to provide them with the following information:

• A detailed description of the nature of the problem
• The name, product description, brand, size and lot code(s) affected
• Details of complaints received and any illnesses reported
• The distribution of the product (local or national)
• When the product was distributed (specific dates)
• Label information on the product(s) that may be recalled
• Name of your operation and contact information of the person who will be dealing with the CFIA
• Name and telephone number(s) for your operation’s after-hours contact

Provide as much detail as possible so that the recall is controlled and contained, for example:

• How much product has been produced and how much has been shipped from your operation
• The names, contact information and the quantity shipped to each buyer, so that you can notify your buyers of the situation
• The Canadian Food Inspection Agency has more information on product recalls

Terms used in good agricultural practice

Lot number: A number or code assigned to uniquely represent a batch or group of inputs, products, animals, crops and/or outputs that have been produced and/or processed or packaged under similar circumstances.

Premises: A parcel of land associated with a legagory, application or location of an item or activity by means of recorded information.

Records to keep

Livestock

Keep complete identification records for livestock and poultry (for example, individual or group identification). Use commodity-approved identification systems for livestock and poultry.

Record and keep on file the following documentation for all livestock and poultry arriving at and leaving the farm:

• Producer name, farm name and/or premises identification
• Product description and quantity
• Livestock and poultry identification
• Transporter/buyer
• Date of shipment

Note: The record requirements above can be verified from a trucking manifest (for example, trucking manifest for cattle, bison and horses).

Fruit, vegetables and field crops

Keep information about the production of each crop, including:

• Application of pesticides (rate, what was applied, concentration)
• Application of nutrient supplements
• Irrigation dates
• Water testing results

Keep information about the harvesting of each crop, including:

• Lot number of product harvested
• Harvest/packing dates
• Specific field harvested
• Person(s) who harvested/packaged the product, if applicable 
• Temporary storage unit, if applicable

Record and keep on file the following documentation for food arriving at and leaving the farm:

• Producer name, farm name and/or premises identification
• Civic address of premises
• Product description, quantity and unit of measure
• Lot number
• Transporter/buyer
• Date of shipment

Note: The record requirements above can also be listed on receiving and shipping documents such as an invoice or bill of lading.

If you have an audit

Be prepared for the auditor to review:

• Production and shipping records
• Your readiness for a recall:
  • Written procedures to follow during a recall including checklists to help staff communicate. For example, record the proces (what, when, who, where, how), a list of key contacts such as the Canadian Food Inspection Agency, BC Centre for Disease Control, your organization's distribution list
  • A journal or diary of any past recalls, or trial runs of your written procedures

Laws and regulations 

A number of laws require producers of certain commodities to register their name, address and location. For example, the Bee Act, s. 9 requires beekeepers to post their name on any apiaries they own. S. 3-4 require beekeepers who have bees or beehive equipment or land to keep bees to register, and s. 3 states inspector may require records relate to the keeping or sale of bees or beehive or beekeeping equipment.

The Food Safety Act, S.B.C. 2002, c. 28, Meat Inspection Regulation, Reg. 349/04, s. 29 (1)-(2) require licensed holders of slaughter establishment to keep records of the name, address and telephone number of the owner of the animals, as well as the location from which the animal was shipped to the slaughter establishment. For poultry, licensed holders must maintain records that show the location from which the flock was shipped, and the name, address and telephone number of the person who owned the flock at the time it was shipped to the slaughter establishment.

Certain livestock (or deadstock) must be individually tagged as required by Health of Animals Act (Canada), 1990, c. 21, Health of Animals Regulations, Part XV Animal Identification s. 175-182. Cattle, sheep and bison must have an approved identifier applied before leaving their farm of origin.

The Canadian Food Inspection Agency has the power to order a food recall for products regulated under Acts that they administer that pose a risk to public, animal or plant health (CFIA Act (Canada), 1997, c. 6, s. 19).

Certain commodities have specific requirements for marking, labelling and identifying individual producer lots in a shipment. The Agricultural Produce Grading Act, R.S.B.C. 1996, c. 11, s. 14 (2) (d) provides that the Lieutenant Governor in Council may make regulations as to how to identify producers of ungraded produce sold or shipped. The Honey Regulation, Reg. 103/78, s. 3 (2) requires the name and address of the person who packed the honey or the first seller must be marked on the container. The Shell Egg Grading Regulation, Reg. 105/78, s. 4 (1) requires the operator of an egg station or an egg product station to maintain complete records including a grading statement for each lot of eggs received from a producer containing the name and address of the producer. Ungraded eggs from each producer must be clearly identified by the receiver at an egg station or egg product station (s. 3 (3)).

Federal labelling requirements for prepackaged foods are set out in the Food and Drugs Act (Canada) 1985, R.S.C., c. F-27 and Regulations; the Consumer Packaging and Labelling Act, R.S.C. 1985, c. C-38 and Regulations; as well as in regulations under the Canada Agricultural Products Act, R.S.C. 1985, c. 20, 4th Supp; and Weights and Measures Act, R.S.C. 1985, c. W-6 that may apply to specific food items.

Forms and samples