The Traceability, Withdrawal & Recall Policy forms part of the Food Industry Hub FSQMS Policies and Procedures Suite. It establishes the governance framework for maintaining effective traceability systems and for the controlled management of product withdrawal and product recall.
The policy applies across products, raw materials, ingredients, packaging, processes and distribution activities within the FSQMS scope. It sets the governing commitments, accountability and decision principles needed to support traceability through receipt, processing, storage and distribution, together with timely and appropriate action where product safety, legality, authenticity or quality risks are identified.
The policy requires products, raw materials and packaging to be traceable through the supply chain. Its scope extends to suppliers, outsourced activities where applicable, internal processing, storage and dispatch under site control.
Traceability systems are required to identify raw materials, packaging, processing history and distribution routes for finished products. The supporting records must be accurate, legible and retrievable, with defined retention periods, so the organisation has controlled traceability information available when it is needed.
The policy requires withdrawal and recall arrangements to be clearly defined, documented and implemented, supported by effective, documented and tested procedures. Traceability systems must enable rapid identification, isolation and control of affected materials or products.
Withdrawal and recall decisions are governed by risk assessment, objective evidence and consumer protection. This keeps the policy focused on the basis for decision-making and the organisation’s commitment to timely and appropriate action when relevant risks are identified, while the detailed operating mechanisms remain within the supporting procedures.
Senior management accepts full accountability for ensuring that traceability, withdrawal and recall systems are implemented, maintained and effective. Its responsibilities include providing the necessary human, financial and organisational resources, approving and supporting withdrawal or recall decisions where required, and ensuring that significant incidents and outcomes are considered through management review.
Managers and supervisors are responsible for implementing and maintaining the procedures that support the policy, applying traceability systems correctly within their areas and promptly escalating potential traceability failures or product safety concerns. Employees are required to follow the procedures relevant to their role and report issues that may compromise traceability or product integrity.
The policy requires the traceability, withdrawal and recall systems to be tested at planned intervals to verify effectiveness and timeliness. Outcomes from traceability tests, withdrawals and recalls are then reviewed and used to support continual improvement.
This gives testing and review a clear governance role: the policy requires the organisation not only to maintain the arrangements, but also to examine their performance and feed relevant outcomes into management review and improvement activity.
Detailed operational controls sit beneath the policy in documented procedures governing traceability, product withdrawal and product recall. Those procedures define the testing requirements, communication protocols and record-keeping arrangements needed to give effect to the policy.
Within the wider FSQMS, this policy therefore provides the governance layer for traceability and incident response while preserving the distinction between management commitment and the detailed procedural controls used in practice.