1.13 Traceability and Recall

When different squash variety or product from a new field is brought to the packing house, there is a pause to let the product from the previous production run finish being packed and a new batch / lot is assigned to the next production run. After the squash is graded and packed into cartons, a Work Order label, provided by Wholesum Organic Farms is applied to the pallets.

Once the pallet is ready to ship to a customer, JAS must make sure that a pallet tag has been printed and affixed to each pallet being shipped. The SSCC pallet tag number will be linked to internal pallet information within JAS and Wholesum Family Farms internal systems.

Recall Program

JAS Family Organic Farms has a Recall action team in place with specific responsibilities to manage any practice and actual recall proceedings initiated by customers. IT shall be tested at least twice annually according to procedures below and also documenting lessons learned.

Roles and Responsibilities

General Manager- Tony Serrano

Shall coordinate with customers during the recall process. The General Manager will delegate the Admin Director to perform any traceback of product and gather all relevant food safety paperwork from fields.

Cell (831)251-1000

email: tony.jasfamilyfarms@gmail.com

Admin Director- Wendy Guzman

Will be in charge of gathering any food safety paperwork from the fields and documenting the Recall Summary Forms and Status Reports.

Cell: (831) 431-3539

email: wendy.jasfamilyfarms@gmail.com

Abigail Melchor, Compliance Specialist

Is in charge of assisting in the process and compliance with or modifications to the plan with General Manager and Administrative Director.

Cell: (831) 750-6350

email: abigail.jasfamilyfarms@gmail.com

Customer Complaints

Any food safety problems and complaints, such as but not limited to moldy, decayed or damaged produce, received by customers will be reported on the Excel file Product Complaint Log (Appendix. P) that is stored in the Administrative Director's desktop. The following details will be included for all customer complaints:

• Date/Time of complaint/rejection

• Who made the complaint/gave feedback,

• Contact information,

• Product description,

• Amount of product,

• Product code/date,

• Nature of complaint/feedback,

• Corrective actions,

• Corrective actions taken to prevent reoccurrence.

Practice Recall

The Recall Summary Log (Appendix R) will be filled out after each practice recall has been performed. Practice recalls will take place twice a year at least every six months. The results of the practice recall will document: 1) % reconciliation of produce, 2) performance of employees and any issues presented, and 3) Lessons Learned. This Log is to be maintained in the JAS Family Farms food safety binder for at least two years.

Notification of Recall

1. When the General Manager is notified of a potential contamination risk of produce, the General Manger will immediately call together the Recall Action Team (RAT) to discuss the circumstances.

2. The RAT team then immediately implements the Traceback Procedures and review of documents to verify if contamination is confirmed. The Administrative Director will assist and oversee the Traceback procedures.

3. If Contamination is NOT confirmed, the Recall Action Team will immediately contact the General Manager of the outcome.

   1. If contamination is confirmed, RAT Team must determine by document check where in the supply chain the contamination happened and classify the contamination as Class 1, 2, or 3. The General Manager will contact all buyers and field employees to place a Hold on the produce.

Determining Class Category of Contamination

Class 1:

An emergency situation in which there is a reasonable probability that the use of, or exposure to, a volatile product will cause serious adverse health consequences or death. Pathogenic organisms such as Clostridium botulinum and Listeria monocytogenes in the product would be given this classification. Abiotic materials such as leachable lead at 400 parts per billion in the product would also be given this classification. Other pathogenic organisms may also be considered in this classification depending upon the specific situation, amount of product distributed, extent of product consumed, age and health of the individuals exposed, etc.

Class 1 recalls shall be made to the consumer or user level (if possible), including any intermediate wholesale or retail level.

Class 2:

A priority situation is the use of, or exposure to, a volatile product may cause temporary or medically reversible adverse health consequences. Or when the probability of serious adverse health consequences is remote. For example, pathogenic organisms exclusive of Clostridium botulinum and Listeria monocytogenes in the product. Other pathogenic organisms, such as Salmonella, Shigella, Staphylococcus aureus, or indicator organisms such as E. coli in the product are candidates for this classification. Again, depending on the specific situation, amount of product distributed, extent of product consumed, age and health of the individuals exposed, other pathogenic organisms may also be considered in this classification. Abiotic materials such as leachable lead in this product at 10 parts per billion would be considered in this classification.

Class 2 recalls shall be made to the retail level, including any intermediate wholesale levels.

Class 3:

A situation in which the use of, or exposure to a volatile product is not likely to cause adverse health consequences, for example, adulterated or misbranded products that do not involve a health hazard. Identification of a container as having 14 ounces of a product when in reality it contains only 10 ounces of product would fall into this category.

Class 3 recalls should be made to wholesale level.

AN UNCLASSIFIED OR VOLUNTARY WITHDRAWAL

Any Unclassified and Voluntary situation of product withdrawal in which no violations are involved, or are of such a minor nature, will not place them under FDA guidelines. Examples may include product quality, packaging, etc.

Real situation interpretation of the Recall Classifications is not always simple or straightforward. The Food and Drug Administration should be contacted when any doubt exists as to the classification of a specific situation

MOCK RECALL

Once a year a mock recall will take place to consider reconciliation of product and efficiency.

Recall Status Report

Once the Class is determined, the General Manager will initiate the Recall Status Reports (Appendix O). This will document the effectiveness and progress of the recall from the potential buyers. Such information shall include the following information when appropriate:

● Number of buyers notified of the recall, and the date and method of notification.

● Number of buyers responding to the recall communication and the quantity of the product(s) on hand at the time it was received.

● Number of buyers who did not respond (the identity of the unresponsive buyers may be requested by the FDA).

● Number of product(s) returned or disposed of by each buyer contacted and the quantity of products accounted for.

● Number and results of effectiveness checks that were made

● Estimated time frames for completion of the recall. (21CFR7.53, Refer to Appendix A of the Code of Federal Regulations)