Food Recall Plan

Recall Plan

In the event that any of our products present a threat to public health or violate the Act and Rules and Regulations made thereunder, SutraOS Technologies Private Limited will protect public health by facilitating the efficient, rapid identification and removal of unsafe food from the distribution chain and by informing consumers of the presence in the market of such food.

There is a documented recall procedure in place and this will be periodically tested to ensure that it is comprehensive and fit for purpose in its ability to remove unsafe food from consumers and/or the distribution chain.

Recall Procedure: Introduction

This procedure states the action/s SutraOS Technologies Private Limited will take to effectively manage the food recall in case the food does not meet the requirements of the hygiene, safety and quality of food as well as protect the health of consumers.

An effective product recall will ensure that unsafe food or food that violates the Act and Rules and Regulations made thereunder is contained and either destroyed or rendered safe.

We will refer to and follow instructions when required which are laid out in the following documents:

• Food Safety and Standards (Food Recall Procedures) Regulation, 2017
• FSSAI Website (www.fssai.gov.in)
• Guidelines for food recall plan

Roles and Responsibilities

It is our SutraOS Technologies Private Limited responsibility to effectively organise and manage the recall of food that presents a threat to public health or food that violates the Act and Rules and Regulations made thereunder and to formulate a broad level recall plan as per FSSAI guideline on recall plan.

The recall co-ordinator for the site is SutraOS Technologies Private Limited who has been given authority from management to make recall decisions on behalf of SutraOS Technologies Private Limited. When a recall is initiated, our actions in recalling the affected food/s need to be co-ordinated with the CEO, FSSAI.

We shall notify the CEO, FSSAI as soon as a recall is likely to be initiated. It is our responsibility to manage the recall by clarifying the food safety issue and the exposure (who and where risk exists), and to provide details on distribution and the method of recall.

The Recall Management Team

The recall co-ordinator SutraOS Technologies Private Limited will initiate the formation of a recall management team and will co-ordinate actions with the CEO, FSSAI and our marketing and distribution agents. Committee members will include personnel from across our SutraOS Technologies Private Limited. Typically, the committee would be like:

The recall management team is responsible for the management of all recall activities and to adhere to this procedure. Duties of the recall management team are to:

• assess the overall problem;
• notify the relevant regulatory authority;
• evaluate the hazard in the food and the extent of contamination;
• determine a strategy to be followed;
• make decisions about product still in manufacture or in storage;
• notify insurers.

Recall Actions & Documentation

The recall management team shall reference and follow the actions outlined in the Food Safety and Standards (Food Recall Procedures) Regulation, 2017 when we become aware a product may be unsafe or food that violates the Act and Rules and Regulations made thereunder. We will ensure that records of all actions and decisions and who was responsible are recorded and retained.

Decision to Recall

The decision to recall will be submitted to the CEO, FSSAI.

Notification of a Product Recall

If the decision is taken to initiate a recall, we will notify:

• Senior management of SutraOS Technologies Private Limited, supply chain personnel
• Food Authority.
• Anyone that has received our product, including distributors, wholesalers, retailers and caterers.
• Consumers, via the media contacts included on our contact list.

The contact list must contain the contact details for the following:

• The products recall committee and senior management and key company personnel.
• Suppliers of all ingredients.
• Downstream Food Business Operator and business customers.
• Sources of technical advice and support including laboratory facilities.
• Regulatory Authorities.

Regaining Control of Affected Stock

The recovered product/s will be stored in an area that is separated from any other food products. Accurate records will be kept of the amounts recovered and the codes of the product/s. If the recovered product/s is unfit for human consumption, it may be destroyed or denatured under the supervision of the company management and/or the regulatory authority where legally required.

If the food safety risk can be safely removed from the recovered product/s through relabelling or reprocessing this may be done once it is clear that public health will be protected.

Recall Status Report

Periodic status reports will be submitted to the CEO, FSSAI after the notification of the recall for assessing the progress of the recall.

The frequency of such reports will be determined by the relative urgency/gravity of the recall and will be specified by the concerned food authority for each recall. However, in any case, the reporting interval shall not be more than 1 week.

The recall status report should contain information specified under Schedule II of Food Safety and Standards (Food Recall Procedure) Regulation, 2017.

Post Recall Report

Recall management team will submit post recall report to the CEO, FSSAI after the completion of the recall to assess the effectiveness of the recall.

In addition, SutraOS Technologies Private Limited will investigate the reasons that led to such recall and will take action to prevent recurrence of the problem.

Termination of a Recall

SutraOS Technologies Private Limited may request termination of the recall by submitting a written request to the CEO, FSSAI along with the latest recall status report stating that the recall was effective.

The recall will be terminated when the concerned food authority determines that all reasonable efforts have been made in accordance with the recall strategy and it is reasonable to assume that the food product subject to the recall has been removed and proper disposition or correction has been made commensurate with the degree of hazard of the recalled food product. Written notification that a recall is terminated will be issued by the Food authority to the company.

In case of unsatisfactory reports, the concerned food authority may consider further action like stepped-up inspection, seizure or any other legal action, against the SutraOS Technologies Private Limited.

Follow Up Action

We SutraOS Technologies Private Limited will submit an interim report as soon as recall is completed to the regulatory authorities within an agreed timeframe of the closure of the recall in any case not later than thirty days after the completion of a recall. The final report will include the elements outlined in the FSS (Food Recall Procedure) Regulation, 2017.