USDA Foods Hold and Recall Process

This Management Bulletin (MB) notifies recipient agencies (RA) and U.S. Department of Agriculture (USDA) Foods processors and distributors that the USDA recently issued Responding to a Food Recall: Procedures for Recalls of USDA Foods. This MB also provides a summary of stakeholder responsibilities.

Responding to a Food Recall contains an overview of the recall process for USDA Foods with a focus on school nutrition programs. Particular attention is paid to the roles and responsibilities of various stakeholders for communicating information and removing recalled food from service to ensure that all involved agencies (the USDA, the California Department of Education [CDE] Food Distribution Program [FDP], RAs, processors, and distributors) manage recalls in a timely and effective manner. You can download the document from the USDA Food Safety Hold and Recall Procedures Web page at https://www.fns.usda.gov/ofs/usda-food-recall-resources.

Roles and Responsibilities

Purchasing and distributing USDA foods is a collaborative partnership between federal agencies, state agencies, and RAs, as well as processors and distributors. Each stakeholder has important roles and responsibilities related to holds and recalls of USDA Foods, as summarized below.

Federal Agency

The USDA Food and Nutrition Service has the following required roles and responsibilities related to USDA Foods holds and recalls:

• Notify the state agency directly about a recall involving USDA Foods as quickly as possible, usually within a few hours of receiving the alert
• Provide the state agency with product identification information to help track the affected product, which may include the vendor name, contract number, sales order number, purchase order number, ship-to city, and quantity
• Contact processors that received recalled bulk product directly from the USDA to alert them to the recall
• Provide instructions—in consultation with the responsible regulatory agency, procurement agency, and vendor—to the state agency on product disposition and the reimbursement process for expenses related to the recall

State Agency

The CDE FDP has the following required roles and responsibilities related to USDA Foods holds and recalls:

• Contact RAs by e-mail as soon as possible, but within 24 hours, after receiving a recall notification
• Provide identification information to track the product and instructions on removing and isolating the affected food.
• Confirm RA receipt of the notification, to the extent possible
• Provide specific product disposal instructions to RAs
• Direct approved in-state processors to isolate affected USDA Foods and determine:
• The amount of recalled product remaining in storage
• The location and amount of product delivered to RAs
• Provide all required forms to the RAs, processors, and distributors
• Compile inventory data from RAs, processors, and distributors and submit the data to the USDA
• Collect recall reimbursement claims and destruction verification forms from RAs, processors, and distributors to submit to the USDA
• Reimburse RAs after receiving the electronic funds transfer from the USDA through the apportionment process, within 90 days or upon receiving Budget Authority  

Recipient Agencies

RAs have the following roles and responsibilities related to USDA Foods holds and recalls:

Required

• Update the FDP Contract packet in the Child Nutrition Information and Payment System (CNIPS) annually and whenever contact information changes
• Notify all school and vended sites of a recall immediately, ideally within 24 hours, and ensure that the affected product(s) are isolated and labeled to avoid accidental use
• Identify the locations of the affected product(s) and verify that the product(s) have the correct product identification codes
• Contact distributors and processors to determine if they received any USDA Foods affected by the recall, if applicable
• Conduct an inventory assessment, ideally within 48 hours, and determine the amount of recalled product:
• Served
• Remaining in stock at schools, warehouses, and distributors
• Further distributed to program participants
• Redirected for further processing (backhauled)
• Submit inventory assessment information to the CDE on a Recall Response Form
• Follow applicable destruction/disposal instructions provided by the CDE
• Submit a Destruction Verification and Reimbursement Form and back-up documentation to the CDE within the required timeframe   

Recommended (Risk if Not Followed or Implemented)

• Implement written procedures for staff to follow in the event of hold or recall         
• Maintain a hold and recall contact list for serving sites and other recipients and verify contacts annually (the list should contain two recall contacts per site)
• Maintain a hold and recall contact list for distributors and processors and verify the list annually

Processors

Processors have the following roles and responsibilities related to USDA Foods holds and recalls:

Required

• Implement recall procedures
• Maintain up-to-date hold and recall contact information in the CNIPS Processor Application
• Identify and isolate all food items produced from the affected USDA Foods immediately upon notification of a recall           
• Contact the CDE, RAs, and distributors that received affected product immediately, ideally within 24 hours
• Provide specific product identification information to the CDE, RAs, and distributors to help them identify affected products
• Conduct an inventory assessment, ideally within 48 hours, of affected product to determine:
• End products made from bulk USDA Foods
• End products shipped
• Remaining USDA Foods in stock, in raw and processed forms
• Compile information received from distributors regarding the quantity of product remaining at the distributor and the quantity of product shipped to each RA
• Submit inventory assessment information to the CDE on a Recall Response Form
• Follow applicable destruction/disposal instructions provided by the CDE
• Submit a Destruction Verification and Reimbursement Form and back-up documentation to the CDE (and the USDA if a national processor) within the required timeframe

Recommended (Risk if Not Followed or Implemented)

• Maintain documentation confirming that the CDE, RAs, and distributors received the recall message
• Notify the the CDE, RAs, and distributors that did not receive affected products about the recall and confirm that they are not affected

Distributors

Distributors have the following roles and responsibilities related to USDA Foods holds and recalls:

Required

• Identify and isolate affected products immediately upon notification of a recall
• Contact the CDE and RAs that received affected product directly and immediately, ideally within 24 hours
• Provide information to the processor regarding the quantity of end products in storage and the amount shipped to individual RAs and other recipients
• Conduct an inventory assessment, ideally within 48 hours, of affected product to determine the amount:
• Shipped
• Remaining in stock
• Submit inventory assessment information to the CDE on a Recall Response Form
• Follow applicable destruction/disposal instructions provided by the CDE
• Submit a Destruction Verification and Reimbursement Form and back-up documentation to the CDE within the required timeframe

Recommended (Risk if Not Followed or Implemented)

• Implement recall procedures
• Maintain up-to-date hold and recall contact information in agreements with the CDE
• Maintain documentation confirming that the CDE and RAs received the recall message  

In the event of an actual hold or recall of USDA Foods, the FDP will provide more specific instructions and all required forms to affected entities.

If you suspect that a USDA-distributed food may be contaminated or harmful in some way, please contact your local health department or the USDA Food Safety Unit by e-mail at foodsafety@fns.usda.gov.

If you have any questions regarding this MB, please contact Amy Bell, Child Nutrition Consultant, FDP, by phone at 916-322-5051 or by e-mail at abell@cde.ca.gov.