EXTENSIONBULLETIN

Model Recall Plan

SEPT. 2017 | EB-429
Table of Contents
Introduction.............................................................................................................................................1
Recall Policy.............................................................................................................................................1
Preparing for a Recall.............................................................................................................................1
Customer/Buyer Contacts.......................................................................................................1
Recall Team...............................................................................................................................1
Traceability Plan.......................................................................................................................1
Mock Recall..............................................................................................................................................2
Recall Procedures....................................................................................................................................2
Identify the Concern................................................................................................................2
Initiate the Recall......................................................................................................................3
Notify the Regulatory Agencies.............................................................................................................3
Identify and Trace Affected Products...................................................................................................4
Notify Affected Parties............................................................................................................................4
Control and Dispose of Recalled Products..........................................................................................5
Determine the Recall’s Effectiveness.....................................................................................................5
Terminate the Recall...............................................................................................................................5
Remedy the Cause and Restore Operations.........................................................................................5
Appendix A: Customer/Buyer Contact list..........................................................................................6
Appendix B: Recall Team Contact List.................................................................................................7
Appendix C: Produce Traceability Plan..............................................................................................8
Appendix D: Mock Recall Exercise.......................................................................................................9
Appendix E: Consumer Complaint Form..........................................................................................11
Appendix F: Recall Plan Checklist......................................................................................................12
Appendix G: Health Hazard Evaluation Questionnaire...................................................................13
Appendix H: Traceability Log..............................................................................................................15
Appendix I: Communication Document Links................................................................................16
Appendix J: Communications Log.....................................................................................................17
Appendix K: Product Retrieval Log....................................................................................................18
References...............................................................................................................................................19

Disclaimer: This model plan is intended to provide general information and should not be construed as providing legal advice.

MODEL RECALL PLAN | i

Introduction
This is the recall plan for _______ Farm. This plan does not address recall provisions related to meat
or egg products. This plan will be periodically updated.

Recall Policy
In the event of a food safety issue related to our products, ______ Farm will protect the public
health by efficiently identifying and removing unsafe food from the distribution chain and informing
consumers of potentially hazardous food in the marketplace. This plan will be tested annually through a
mock recall to ensure it functions effectively.

Preparing for a Recall

CUSTOMER/BUYER CONTACTS

Appendix A contains a list with the names and available contact information for all customers/buyers
of our products. ______ Farm will use this list to contact customers in the event of a recall and will
update the list as needed.

RECALL TEAM

The list in Appendix B describes the various roles of the Recall Team, the staff members assigned each
role, and the contact information for the regulatory agencies involved in a recall. The Recall Team is
responsible for coordinating all aspects of a product recall. The roles and responsibilities of each Recall
Team member are as follows:
n Recall Team Leader – has the ultimate authority to make the decision to initiate a recall, make critical
decisions quickly, and designate team members as needed.
n Recall Team Coordinator – oversees the complaint investigation and the trace-back process, and
coordinates the recall team to address the issues at hand.
n Government Liaison – contacts the regulatory agencies, is knowledgeable about the farm’s
traceability procedures, and is prepared to provide the necessary information, as well as able to
access related records and documents
n Media/Customer Spokesperson – disseminates information about the recall to the media and
customers, and handles press releases, social media, etc.
n Legal Counsel – provides legal advice in the event of a recall or food safety event, is familiar with our
farm, and has reviewed this recall plan.
n Insurance Agent – provides information relating to insurance coverage.

TRACEABILITY PLAN

Appendix C contains a copy of our traceability plan. Being able to effectively trace products is a key
component of a recall. Our farm utilizes a system that allows us to trace products one step forward
and one step back. We keep records of all our agricultural inputs including soil amendments, fertilizers,
seeds/transplants, and agricultural chemicals so we can link them with each of our crop types and
ultimately to our buyers. We also assign our products a traceability code (lot number) based on harvest
date, crop, and field number.

MODEL RECALL PLAN | 1

Mock Recall
Once during each growing season, we conduct a mock recall for our farm and markets which mimics
the process of an actual recall. We use mock recalls to determine whether the recall plan and procedures
are capable of 1) identifying and quickly controlling a given lot of potentially affected product and 2)
reconciling the quantities produced, in inventory, and distributed. A mock recall will help us evaluate
the effectiveness of our plan and procedures by identifying potential problems and ensuring employees
are familiar with recall procedures. Appendix D lists the materials used during a mock recall. If
problems are identified during the mock recall, this plan will be amended.

Recall Procedures
In the event of a recall, the Recall Team Leader will take the following steps to ensure successful
retrieval of products, communication with all necessary parties, and restoration of normal business.

IDENTIFY THE CONCERN

A recall may be initiated in a few ways: 1) consumer complaint(s); 2) notification by a regulatory

agency of a food safety issue; or 3) an internal operations discovery or laboratory report indicating a
potential food safety issue.
We take all consumer complaints related to our products very seriously and record them on a
Consumer Complaint Form in Appendix E. The employee who takes the call should ask all questions
on the Consumer Complaint Form and record all pertinent information. As soon as possible after
receiving the complaint, the employee is required to inform the owner/manager of ________Farm and/
or the Recall Team Leader.
After receiving a consumer complaint, notification by a regulator of a food safety issue, or an internal
discovery of a condition that could create a food safety risk, the owner/manager of _______ Farm and/
or the Recall Team Leader will assess the severity of the issue. If the consumer complaints are related
to adverse health effects caused by the farm’s products, we will use the Health Hazard Evaluation
Questionnaire in Appendix G to assess the concern. In addition, __________ Farm will also assess
the concern by consulting the Maryland Department of Agriculture’s (MDA) Food Quality Assurance
Department at 1-410-841-5769 or after hours at 443-223-9408.
The speed with which the health hazard must be evaluated will depend on the nature of the alleged
violation or defect. The more serious the potential health effects, the greater the need for an urgent
response. If _______ Farm receives more than one consumer complaint about adverse health effects
caused by one of our products, we will consider the situation to be a potential foodborne disease
outbreak and will contact the local health department.
When contemplating a recall, the owner/manager of _______ Farm and/or the Recall Team Leader
will also contact legal counsel for advice pertaining to the applicable legal standards before deciding to
initiate a recall.
If no risk is found after a thorough investigation, a consumer complaint may be handled internally
and no further action may be necessary. If the investigation determines there may be a minimal risk
associated with a product which is not likely to cause adverse health consequences (such as improper
labeling), the product will be removed from the market and the issue corrected. However, if ______
Farm finds a potential risk of adverse health consequences from one of our products or that a product is
adulterated or misbranded, a recall will be initiated. In the case of a potential recall, the owner/manager

MODEL RECALL PLAN | 2

 of _______ Farm and/or the Recall Team Leader must document all information available to support the
decision—either to recall, or not.
If _______ Farm is notified by the county health department, the Maryland Department of Health,
the MDA, or the federal Food and Drug Administration (FDA) that our products could be implicated
in a foodborne illness outbreak, we will make a record of the communication, assemble the recall
team, contact our legal counsel and insurance agent, if applicable, and start an internal investigation in
coordination with the agencies.

INITIATE THE RECALL

After the decision to initiate a recall, the Recall Team will assemble, notify regulatory agencies (if not
previously notified), and determine the recall’s scope. To determine the class and scope of the recall,
_______ Farm will consider 1) whether any disease or injuries have already occurred from use of the
product; 2) the seriousness of the health hazard; 3) the immediate and long-range consequences; and
4) the ability to identify and quantify the defective product in the marketplace.

_______ Farm will use the following FDA class levels of recall:

n Class I: A situation where serious (possibly even fatal) health consequences may result if the product
is consumed. Examples include Listeria or Salmonella in food. A public alert is usually issued.

n Class II: A situation where a health hazard might exist but the probability is remote. A public alert
may be issued. An example is a food containing an undeclared allergen.

n Class III: A situation where a food violates federal regulations, but is unlikely to cause adverse health
consequences, and where a public alert is not usually issued. An example is a food with a minor
labeling issue.

n Market Withdrawal: A situation where a food has a minor violation that is not in violation of any
food safety laws. The products may be withdrawn from the market without initiating a recall.

The Recall Team will use the Recall Plan Checklist in Appendix F to stay on track of all necessary steps
in the recall process.

Notify the Regulatory Agencies

When the decision to initiate a recall based on consumer complaints is made, the Government Liaison
member of the Recall Team will contact the county health department. If the issue is serious or life-
threatening, the Government Liaison will call the FDA’s 24-hour emergency line at 1-866-300-4374 or
301-796-8240. If the Recall Team initiates a recall because of an internal discovery, the Government
Liaison will also contact the MDA’s Food Quality Assurance Department at 1-410-841-5769 or after
hours at 443-223-9408. The federal, state, and local regulatory agencies will work with ________Farm
on the recall process. Appendix B lists the contact numbers for the regulatory agencies.

MODEL RECALL PLAN | 3

Identify and Trace Affected Products
Identifying and tracking affected products are crucial during a recall and will be done in accordance
with _______ Farm’s traceability plan. The Recall Team Coordinator will initiate trace-back procedures
to determine the products, number of units, units of measure, farm, harvest date, and lot numbers
involved. All information pertaining to the trace back will be recorded in the Traceability Log found
in Appendix H. The Coordinator will also collect all pertinent documentation regarding the affected
product such as inputs and outputs of the field associated with the lot number, harvesting methods, and
any other details that could aid in the investigation (for example: ill employees). The Government Liaison
will work with the Coordinator to make sure the required information is provided to the overseeing
regulatory agencies throughout the investigation.

Notify Affected Parties

The Media/Customer Spokesperson member of the Recall Team will work with the overseeing
regulatory agencies to send out all press releases and customer notifications. If the products pose a
significant health hazard and the recalled products are in the hands of consumers, a press release is
usually appropriate.

_______ Farm will notify all wholesale, retail, and direct customers as soon as possible about the
recall. Notifications will be done through a telephone call, in person, or in writing (the preferred form of
notification). If produce was distributed at a farm-owned retail stand, a notice will be posted there. See
Appendix I for a form to use for recall notification by telephone.
The notification must include:
n A complete description of the product and any codes used to identify the product,

n A description of the problem and any potential associated health hazards,

n The scope of the recall (wholesale, retail, or user level),
n Clear instructions regarding removing the product from sale, ceasing distribution, sub-recalling
(if appropriate), returning the product, or modifying the product, and
n A return response form for all written notifications so that customers can indicate they received the
notification and followed the instructions.

Links to model press releases and recall notifications can be found in Appendix I. _____ Farm will
retain evidence of all communications. We will record all communications during the recall in the
Communications Log found in Appendix J.

Control and Dispose of Recalled Products

The Recall Coordinator or a designated member of the Recall Team is responsible for ensuring all
recalled products are controlled and disposed of appropriately. ______Farm will make all reasonable
efforts to remove affected products from the commerce stream.
All affected products still in the control of _______ Farm (e.g., inventory located onsite, in transit,
in off-site storage, and in off-site distribution) will be detained and segregated to prevent reentry into
the commerce stream. The Team will document all quantities and identification codes to help with

MODEL RECALL PLAN | 4

 reconciling product amounts and will clearly mark all affected product “not for sale or distribution.”
_________ Farm will work with the overseeing regulatory agencies to decide on the appropriate
disposition of recovered recalled products. Products deemed unsafe for human consumption may be
returned, destroyed, and disposed of by appropriate means. No products will be destroyed without first
notifying the regulatory agencies. The team will quarantine all returned products until the recall ends.
The Recall Coordinator or another member of the Recall Team will document quantities, identification
codes, and disposition on the Product Retrieval Log in Appendix K.

Determine the Recall’s Effectiveness

The Recall Team will need to determine the level of the recall’s effectiveness. To do so, the team will
perform and document effectiveness checks of the recall to prove that all known, affected customers
were notified of the recall and have taken appropriate action. See links to model effectiveness check
documents in Appendix I.

Terminate the Recall

For the recall to be terminated, the Recall Team will need to evaluate whether all possible customer
responses have been received and if it is reasonable to assume that the recalled product has been
recovered, corrected, reconditioned, or destroyed. The overseeing regulatory agencies will notify ______
Farm when the recall is terminated.

Remedy the Cause and Restore Operations

As soon as the Recall Team identifies the reason for the recall, it will take corrective and/or
preventative measures to remedy the issue. After the recall, the team will update, revise, and make all
necessary amendments to this plan. Finally, _______ Farm will focus on fully restoring operations.
______ Farm will not only remedy the physical issues associated with the cause of the recall but will
also focus on rebuilding public trust in our products. Upon completion of a recall, the Media/Customer
Spokesperson member of the Recall Team will craft a statement announcing the end of the recall to
advise customers that they may once again enjoy our products.
Following a recall, ______ Farm will assess what changes, if any, need to be made to this plan to make
it more efficient and effective.

MODEL RECALL PLAN | 5

Appendix A: Customer/Buyer Contact list

Customer/buyer Business
Address Email Mobile phone Product sold
name phone

Source: Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted for UVM by Ginger Nickerson)  
https://www.uvm.edu/~susagctr/whatwedo/producesafety/GAPsResources/gapresRTSampleRecallPlanMarch62016GNRevised.docx.

MODEL RECALL PLAN | 6

Appendix B: Recall Team Contact List

Business After Hours Responsibilities

Role Name
Phone Phone During Recall

• Serves as recall team leader

• Makes final decisions on recovery
Recall Team Leader
of products
• Reassigns team members

• Oversees complaint investigation

Recall Team
Coordinator • Coordinates the recall team
actions

• Communicates with regulatory

agencies and works with legal
Government Liaison
counsel and provides information
to regulatory agencies

• Handles all media and customer

communication
Media/Customer
Spokesperson • Works with regulatory agencies
on press releases and customer
letters

• Handles liability questions

Legal Counsel • Advises government liaison on
regulatory responses

• Addresses insurance
Insurance Agent
coverage issues

Local Health Dept.

(Contact info for Md.
health departments:
http://dhmh.
maryland.gov/Pages/
departments.ASPX)

• Oversees recalls for food

MD Dept. of Ag. 410-841-5769 443-223-9408
distributed intrastate

State of Maryland
• Oversees recalls for food
MD Dept. of Health Rapid Response 410-767-8400 410-795-7365
distributed intrastate
Team

• Oversees all product recalls for

FDA Baltimore Recall FDA-regulated product within the
410-799-5414
District Office Coordinator Baltimore District (MD, D.C., VA,
WV)

FDA Emergency 1-866-300-4374 301-796-8240

MODEL RECALL PLAN | 7

Appendix C: Produce Traceability Plan

Trace back records: Our farm uses a traceability system allowing us to trace a product one step forward and one step
back. We keep records of all our agricultural inputs including soil amendments, fertilizers, seeds/transplants, and
agricultural chemicals so that we can link them with each of our crop types and ultimately, if necessary, to the buyer(s).

[DESCRIBE YOUR SYSTEM HERE – THIS IS AN EXAMPLE – YOUR SYSTEM AND THE INFORMATION YOU
RECORD MAY BE DIFFERENT]

1. All products produced by the farm will be assigned a traceability code (lot number) based on harvest date, crop, and
field number.

2. Harvested product will be tagged, stamped, or labeled by marketing unit (examples: bin, box, case, pallet, bag, etc.) to
show the following information:

a. The type of crop

b. The name and address of our farm

c. The field the crop was grown in [IF APPLICABLE]

d. The harvest date [OR PACK DATE- WHICHEVER YOU USE ON YOUR LABELS]

e. The lot number [IF USED]

3. All product is invoiced as it is shipped from the farm.

4. Invoices include: farm name and information, buyer name and information, and inventory amounts transferred/
exchanged.

5. Invoice should be signed or initialed by the customer (receiving party) when product is delivered.

6. All unused/unsold inventories are accounted for including quantity, date, and method of disposal.

We use a lot number system which identifies the harvest date and field (example: 072417-2 means harvested on July 24,
2017 from field 2. Add any other information you use in your lot tracking system.) When we make a sale, the invoice
includes information on boxes shipped, to whom, the date of shipment, and the harvest date and field code number.
We keep copies/have electronic copies of all invoices so that the buyer and our farm have the same information. If
a product is comingled during or after harvest, the above label information for EACH crop type and block of land is
provided to the buyer.

Source: Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted for UVM by Ginger Nickerson)  https://www.uvm.
edu/~susagctr/whatwedo/producesafety/GAPsResources/gapresRTSampleRecallPlanMarch62016GNRevised.docx.

MODEL RECALL PLAN | 8

Appendix D: Mock Recall Exercise

Once during each growing season, we conduct a trace forward/mock recall exercise to verify that we can match each lot
sold to the specific buyer and that we can recall a product if needed. As part of the exercise, we contact a buyer to identify
a load received from our company. Make sure to inform the buyer that this is a mock recall exercise! We ask how much
of the product has been sold, how much they have in inventory, and if any has been disposed of for other reasons (fell
on floor, etc.). This information is recorded on our Mock Recall form and kept on file. After a selected lot is sold and
shipped, we go through our records to verify that we can match each box shipped to the destination buyer.

Our goal is to achieve 100% effectiveness of reconciliation of product to recipients within ___ hours. The percent
effectiveness of the recall is calculated in the following way:

A = total amount of product

B = amount still in inventory

C = amount delivered to customers

D = incidental usage if any (e.g. product dropped on ground, etc.…)

(B+C+D) / A x 100 = % effectiveness of recall

The gwoal of the exercise is to demonstrate that we have open communication with our buyers and if necessary, we can
work with them to remove any of our shipped products from their inventory.

MODEL RECALL PLAN | 9

Mock Recall Log

Date Buyer/customer name Buyer contact info

Amt. Amt. of Amt. of

Date & Amt. of
shipped, product product
ID/ Harvest Ship time of product
Product PO #, & remaining sold by Initials
Lot # date date buyer returned/
container in buyer buyer &
contact destroyed
type possession to whom

Comments:
 Determine the percent effectiveness of the (mock) recall.
The total amount of suspect product must equal the sum of the product shipped and the amount still in
inventory.

A – Total amount of product produced

B – Amount still on inventory
C – Amount delivered to customers
D – Incidental usage (product dropped on ground, etc.)

Source: Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted for UVM by Ginger Nickerson)  https://www.uvm
edu/~susagctr/whatwedo/producesafety/GAPsResources/gapresRTSampleRecallPlanMarch62016GNRevised.docx.

MODEL RECALL PLAN | 10

Appendix E: Consumer Complaint Form

Name of person who received call: ______________________________________________________________________

Date and time of incoming call: ________________________________________________________________________

Name of person calling: ______________________________________________________________________________

Contact phone number for person calling: _______________________________________________________________

Name/contact information of person ill or injured, if not caller: _______________________________________________

Age of person ill or injured: ___________________________________________________________________________

Allergies or pre-existing conditions of consumer: __________________________________________________________

Description of the consumer’s complaint (odor, color, taste, allergic reaction, object in food, illness, etc.:
_________________________________________________________________________________________________

Injured person’s symptoms: ___________________________________________________________________________

Date and time symptoms occurred:_____________________________________________________________________

Date the consumer saw a doctor, if any: __________________________________________________________________

Doctor’s name and contact information:__________________________________________________________________

Doctor’s diagnosis: __________________________________________________________________________________

Description of the product the consumer is complaining about (include specific packaging info/product codes, etc.)
_________________________________________________________________________________________________

Amount of the product consumed: _____________________________________________________________________

Names of other consumers of the product:________________________________________________________________

Symptoms of other consumers, if any:___________________________________________________________________

Date and location of product purchase:__________________________________________________________________

Storage of the product before consumption:_______________________________________________________________

Use of or preparation of the product before consumption: ___________________________________________________

Other agencies/persons the consumer has notified___________ Contact information _____________________________

_________________________________________________________________________________________________

Status of any remaining product _______ If there is remaining product, tell the injured person not to dispose of the
product and ask if the farm could retrieve the product for testing.

Any specific requests from the consumer:________________________________________________________________

_________________________________________________________________________________________________

Source: Douglas L. Archer, Keith R. Schneider, Ronald H. Schmidt, W. Steve Otwell, Renee M. Goodrich, and Chris Thomas, The Food Recall Manual, The University of
Florida, http://edis.ifas.ufl.edu/pdffiles/fs/fs10800.pdf.

MODEL RECALL PLAN | 11

Appendix F: Recall Plan Checklist

BEFORE A RECALL:

c Create a Customer/Buyer Contact list (Appendix A). Update names, phone numbers, and emails annually or as needed.

c Create a Recall Team Contact list (Appendix B) including names and phone numbers of recall team and regulatory agencies.

c Create an effective Produce Traceability Plan and Mock Recall exercises (Appendices C & D).

ONCE A PROBLEM IS IDENTIFIED:

c Collect information and consider the health hazard evaluation factors:

• Document consumer complaints using Consumer Complaint Form (Appendix E).
• Consider the health hazard evaluation factors using Health Hazard Evaluation Checklist (Appendix G).

c Consult with the county health department if we have received more than one consumer complaint about adverse health
effects caused by one of our products.
c Consult with the Maryland Department of Agriculture’s Food Quality Assurance Department.

c Consult with legal counsel.

c Determine actionable items: Is this a recall? Market withdrawal? Or handled internally by correction (repairing,
relabeling, or other adjustments to product)?

RECALL DECISION:

c Activate the Recall Team

c Contact the proper regulatory agencies and provide information

c Perform trace-back procedures to determine the product(s), number of units, units of measure, farm, harvest date, and
lot numbers involved (one commodity, or one day, all commodities, etc.) (Appendix H).
c Collect pertinent documentation regarding the affected product.
• Inputs and outputs of affected field associated with the lot number such as notes on harvesting methods, wildlife activity, ill employees,
manure application, etc.

c Work with regulatory agencies to initiate necessary recall notice, customer notifications, and press release (Appendix I).

c Record all communications related to the recall (Appendix J).

c Track, remove, and dispose of recalled products (Appendices H & K).

c Determine the percent effectiveness of the recall.

c Determine if the recall is over/terminate.

c Update the recall plan if necessary.

c Restore operations.

Source: Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted for UVM by Ginger Nickerson) https://www.uvm.
edu/~susagctr/whatwedo/producesafety/GAPsResources/gapresRTSampleRecallPlanMarch62016GNRevised.docx.

MODEL RECALL PLAN | 12

Appendix G: Health Hazard Evaluation Questionnaire

To perform the health hazard evaluation, work through all questions below and attach all supporting documentation.

1. What is the nature of the violation or defect—adulterated product (physical, chemical, or microbial contamination),
misbranded product, improperly labeled product, etc.?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

2. What illnesses or injuries have already occurred from use of the product?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

3. What documentation is there to support the association of the illnesses or injuries with the use of the product?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

4. Was the product used in conformance with its labeled directions for use? If so, were the illnesses or injuries due to a)
product quality (contamination); b) inadequate directions for use; or c) other known or unknown causes?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

5. Are there any existing conditions that could contribute create a health hazard? If so, name the specific conditions (ex.
unsafe irrigation water) and explain how these conditions could contribute to a health risk. Document harvest dates,
irrigation water source, use of biological soil amendments, mechanical or machine harvest, field pack or packing house,
water used post-harvest, or any other processes which could result in product contamination to adequately evaluate
existing conditions.

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

������������������������������������������������������������������������������������������������

6. What segments of the population— children, elderly, expectant mothers, persons with compromised immune systems,
etc. — could be exposed to the affected product? What is the degree of seriousness of this hazard to these specific
population segments?

______________________________________________________________________________________________________________________________

______________________________________________________________________________________________________________________________

MODEL RECALL PLAN | 13

7. What is the degree of seriousness of the health hazard to which the population at risk would be exposed (life
threatening, severe, moderate, limited, or none)? Express in terms of:

A. Life threatening: death could occur

B. Severe: permanent significant disability
C. Moderate: transient but significant disability; permanent minor disability
D. Limited: transient minor disability; annoying complaints
E. None: no disability or physical complaints anticipated

_________________________________________________________________________________________________

_________________________________________________________________________________________________

8. What is the likelihood of occurrence of the hazard? What is the frequency of illness or injuries or other adverse
reactions which have already occurred? If no illnesses or injuries have occurred yet, what is the likelihood of occurrence
in each segment of the population at risk?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

9. What are the immediate or long-term consequences of occurrence of the hazard?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

For more information see, 21 C.F.R. 7.41- Health Hazard and Recall Classification.

MODEL RECALL PLAN | 14

Appendix H: Traceability Log

SHIPPED TO
Quantity shipped
Lot number/ Date Quantity
Product Lot quantity Name/location and requiring
code/date shipped left on-farm
recovery

0
TOTAL =

Source: Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted for UVM by Ginger Nickerson)  https://www.uvm.
edu/~susagctr/whatwedo/producesafety/GAPsResources/gapresRTSampleRecallPlanMarch62016GNRevised.docx.

MODEL RECALL PLAN | 15

Appendix I: Communication Document Links

MODEL PRESS RELEASES (FDA)

Allergens: http://www.fda.gov/Safety/Recalls/IndustryGuidance/ucm129262.htm

Clostridium botulinum: http://www.fda.gov/Safety/Recalls/IndustryGuidance/ucm129273.htm

E. coli 0157:H7: http://www.fda.gov/Safety/Recalls/IndustryGuidance/ucm129287.htm

Listeria monocytogenes: http://www.fda.gov/Safety/Recalls/IndustryGuidance/ucm129267.htm

Salmonella: http://www.fda.gov/Safety/Recalls/IndustryGuidance/ucm129275.htm

MODEL NOTIFICATION LETTERS/ENVELOPE

Envelope: http://www.fda.gov/downloads/Safety/Recalls/IndustryGuidance/UCM214973.pdf

Letter: http://www.fda.gov/downloads/Safety/Recalls/IndustryGuidance/UCM214960.pdf

Return Response Form: http://www.fda.gov/downloads/Safety/Recalls/IndustryGuidance/UCM214967.pdf

MODEL EFFECTIVENESS LETTERS

Check Letter: http://www.fda.gov/downloads/Safety/Recalls/IndustryGuidance/UCM214958.pdf

Effectiveness Check Questionnaire: http://www.fda.gov/downloads/Safety/Recalls/IndustryGuidance/UCM214971.pdf

Check Response Format: http://www.fda.gov/downloads/Safety/Recalls/IndustryGuidance/UCM214963.pdf

MODEL RECALL PLAN | 16

Appendix J: Communications Log

Quantity Action taken and

Quantity Quantity
shipped and Date/ time Person description (e.g., Quantity
recovered or remaining
requiring contacted picked up, returned, recovered
destroyed with contact
recovery destroyed, etc.)

0
TOTAL =

Source: Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted for UVM by Ginger Nickerson)  https://www.uvm.
edu/~susagctr/whatwedo/producesafety/GAPsResources/gapresRTSampleRecallPlanMarch62016GNRevised.docx.

MODEL RECALL PLAN | 18

Appendix K: Product Retrieval Log

Recall
Company or By By In Copy on Reason or
Contact team-
organization phone letter person file description
member

Source: Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted for UVM by Ginger Nickerson)  https://www.uvm.
edu/~susagctr/whatwedo/producesafety/GAPsResources/gapresRTSampleRecallPlanMarch62016GNRevised.docx.

MODEL RECALL PLAN | 17

References

21 C.F.R. § 7.40-7.59 (2017).

Md. Code Regs. 10.06.01.02B(10) (2017).

Md. Code Regs. 10.06.01.09B (2017).

Douglas L. Archer, Keith R. Schneider, Ronald H. Schmidt, W. Steve Otwell, Renee M. Goodrich, and Chris Thomas, The
Food Recall Manual, 2004, The University of Florida, http://edis.ifas.ufl.edu/pdffiles/fs/fs10800.pdf.

Diane T. Ducharme, Draft Recall Plan Workbook, March 2016, North Carolina State University, (Adapted
for UVM by Ginger Nickerson)  https://www.uvm.edu/~susagctr/whatwedo/producesafety/GAPsResources/
gapresRTSampleRecallPlanMarch62016GNRevised.docx.

FDA Industry Guidance, Guidance for Industry: Product Recalls, Including Removals and Corrections, November 3,
2003, https://www.fda.gov/Safety/Recalls/IndustryGuidance/ucm129259.htm.

FDA, Guide to Produce Farm Investigations (11/05), May 3, 2006, https://www.fda.gov/ICECI/Inspections/

InspectionGuides/ucm074962.htm.

Philip Gruber, Farmers Should Plan for Food Recall (Apr. 16, 2015), Lancaster Farming, http://www.lancasterfarming.
com/news/main_edition/farmers-should-plan-for-food-recall/article_85dc2db6-7aee-5ad2-8759-c93335127d9c.html.

Winifred W. McGee & Lynn F. Kime, Penn State Extension, Proactive Recall Plans, http://extension.psu.edu/business/
farm/management/risk/my-food-venture-risk-management-plan/proactive-recall-plans.

Sample Recall Plan, California Department of Public Health, https://archive.cdph.ca.gov/pubsforms/Documents/

fdbRIgde23.pdf.

MODEL RECALL PLAN | 19

Authored By:
(ALEI) is a collaboration of the University
of Maryland Francis King Carey School
of Law at the University of Maryland,
Baltimore (UMB); the College of Agriculture
& Natural Resources at the University of
Ashley Ellixson Maryland, College Park (UMCP); and the
Vice President of Legal & School of Agricultural and Natural Sciences
at the University of Maryland Eastern
Dairymen of Arizona* Shore (UMES). ALEI is an initiative of the
University of Maryland: MPowering the State,
a strategic alliance between UMB and UMCP

research, business development, and student

opportunities at both universities.

University of Maryland College of

Agriculture and Natural Resources
Department of Agricultural and
Sarah Everhart Resource Economics
Legal Specialist 2200 Symons Hall
College Park, MD 20742
(301) – 405-3541

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*This publication was written while Ashley Ellixson was an www.umaglaw.org

Extension Legal Specialist with University of Maryland. Twitter: @MDAgLaw

MODEL RECALL PLAN | 20