Challenges

Traceability is an essential requirement to be able to recall products that are not safe to eat or have non-conformaties that affect the product’s properties. Rapid product recall and sharing information are crucial if we are to prevent or minimise an outbreak of illness caused by a product.

A recall is when a product with defects that violate food safety, have reached the end consumer and is removed from the marked. A withdrawal is product with the same characteristic but are removed in the supply chain before it has reached the consumer.  

Our ambitions in this area

The Group’s ambitions is to take preventive action and have zero Lerøy product recalls.

How we take action/what action has been taken

Lerøy has established product recall procedures that specify in detail what to do if a non-conformity is detected in a product once it has left the company. Product recalls are defined according to the type of non-conformity and the risk category. Lerøy has also established both central and local emergency preparedness groups to manage product withdrawals. This allows us to develop the routines and competencies required for efficient product withdrawals.

The Group conducts preparedness/recall tests every year to make sure that the procedures work properly.

The preparedness group for the Group consists of:

• CEO
• COO Farming
• COO VAP, Sales and Distribution
• Technical Director
• Head of ESG and Quality
• Head of Public affairs
• Group Director HR
• Head of procurement
• Head of IT Systems

The core & responsible of the preparedness group comprises of the CEO and Head of Quality and Sustainability. The other members are invited to meetings depending on the items to be discussed – Farming, VAP/ Sales, Fisheries or processing. The preparedness group has primary responsibility, both internally and externally, for communications and handling of any relevant challenges/crises.

Preparedness plans are also drawn up locally. All facilities have a local preparedness group if a recall should be necessary. The preparedness group consists of persons representing all parts of the operations. 

The typical procedure for product recall consists of the following phases: 

1. Written explanation of nonconformance
2. Classification:
   
   -Class I: Need for information 
   -Class II: Other faults/nonconformances in the product 
   -Class III: Products representing a health risk 
   
   
3. Notify manufacturer and management/preparedness team
4. Tracking product and other relevant batches, 
5. Verify nonconformance, i.e with external expertise (lab) 
6. Notify customers and authorities
7. Written explanation of what is to be recalled
8. Set plan to handle logistic
9. Set plan to handle further use/destruction
10. Corrective action to prevent recurrence

How we measure our impact

All product recalls and withdrawals are recorded in the company’s quality system, LQMS, by all Group companies, and statistics are monitored centrally. If any recall occur an action plan finding the rout cause and actions to eliminate it must be described and followed up in the system.

We have a target of 0 recalls since this has the highest impact on the market, no target has been set for the number of withdrawals as these are products that have not reached the market and are proof that our tracking routines and control work.

Lerøy will always perform recalls if our product does not meet our foodsafety requirements, either as a precautionary or an corrective action.

Lerøy has not identified any non-concompliance with regulations and/or voluntary codes in 2022. 

Every year the Group performs a traceability / recall tests to verify that the traceability and recall system works correctly and efficiently, our recall procedure can be initiated and operated at any time and required finalized within 4 hours. It is essential to train employees and improve recall procedures to be able to ensure an efficient recall regarding food safety if a real case should occur.

A traceability test/recall test is a fictive case related to food safety, which includes: Processing facility, harvest facility, farming including juvenile stations, feed supplier, sub suppliers, the authority and customers. All actors must supply correct documented information. It is also checked if relevant key contact/ out of hours contact details are up to date and correct.

After a recall test, a summary is compiled by the preparedness group and improvement points are identified and implemented. A recall has a time limit of maximum 4 hours.

The Quality Manager at the production facility (QMP) together with the quality Manager at the sales department (QMS) are responsible to ensure that all recalls are carried out according to the recall procedure. QMP and QMS are also responsible involving correct personnel, external expertise and recover documentation required ( analytical reports, quality assurance log, traceability information etc).

Target and result 

In 2022, 11 batches of Lerøy products where recalled from the marked.

All recalls where related to minor batches of sushi products of our own sushi production. 2 recalls related to detection of listeria, 2 recalls cause of error on label, 1 recall of bad packaging and 6 recalls due to bones/foreign objects.

All recalls had limited negative effects since recall was carried out according to procedure and no products where consumed. All recalls where voluntary, had no consumer fatilities or sicness and had limited cost cause of limited batches.

In all recalls corrective action with root cause where carried out to prevent recurrence. Additional visual and physical control points on the production line with verification will prevent products with bones/foreign bodies in the finished package.