Modern Dairy Raw Milk Recall Management Policy

1. Introduction

To strengthen food safety supervision, avoid and reduce the harm of unsafe food, protect consumers’ health and safety, this management procedure is formulated in accordance with the “Product Quality Law of the People’s Republic of China,” “Food Safety Law of the People’s Republic of China,” “Special Provisions of the State Council on Strengthening the Supervision and Administration of Food and Other Product Safety,” and other laws and regulations.

2. Scope of Application

This policy applies to all farms operated by Modern Dairy, including subsidiary farms, leased farms, minority equity investment farms, and entrusted management farms.

3. Responsibilities and Authorities

3.1 Quality Assurance Department

Responsible for establishing and updating the product recall management policy;
Responsible for conducting random checks and verifications on the implementation of the requirements of this policy;
Responsible for assisting various departments in carrying out product recall work.

3.2 Subsidiary

Responsible for the execution, implementation, and evaluation of the management requirements of this policy;
Responsible for assisting the Quality Assurance Department in carrying out product recall work.

3.3 Raw Milk Sales Department

Responsible for assisting various departments in implementing product recall work;
Responsible for issuing product recall announcements.

4. Raw Milk Product Recall Procedure

4.1. Establish a Raw Milk Product Recall Team

Under the company’s “Food Safety Team”, establish a “Food Recall Command Team”, led by the company’s management and composed of department heads, deputy general managers, farm general managers, and regional general managers.

The team leader is responsible for initiating the recall procedure, organizing relevant departments to evaluate unsafe food, and proposing final disposal opinions for recalled raw milk products and reporting to the group center.
The deputy team leader is responsible for supervising the specific implementation of recall activities and promptly reporting results evaluation and recall progress to the team leader.
The Milking Department is responsible for customer complaint information feedback and notification and implementation of unsafe raw milk recall.
The Quality Control Department and Production Department analyze the causes of recalled raw milk products and take corresponding corrective measures.
When necessary, the Human Resources and Administration Department is responsible for reporting raw milk quality and safety issues and recall information to the local quality supervision bureau.

4.2 Raw Milk Product Recall Assessment

4.2.1 Raw Milk Product Quality and Safety Confirmation

Passive Recall
- When a customer complains about the quality of raw milk after it leaves the farm, the Milking Department immediately notifies relevant departments of the farm and the group center, and fills out the “Customer Complaint and Handling Record.”
- Upon receiving the notification, the Quality Control Department immediately retests and evaluates the relevant raw milk samples and fills out the “Non-conforming Raw Milk Review and Disposal Form.” After confirming that the test results are correct, they report to relevant leaders, and the Milking Department implements the recall.
Active Recall
- When the Quality Control Department and relevant production departments discover potential food quality and safety hazards in raw milk that has left the farm after investigation and evaluation, they promptly report to relevant leaders and the head of the Milking Department by phone, while simultaneously filling out the “Non-conforming Raw Milk Review and Disposal Form” and transmitting it to the head of the Milking Department, who implements the active recall.

4.2.2 Food Safety Hazard Assessment

The food contamination, foodborne illness, or harm to human health caused by the food, or the possibility of causing the above hazards.
The impact of unsafe food on the main consumer groups.
The severity and urgency of the hazard.
Short-term and long-term consequences of the hazard.

4.3 Confirm the Severity and Urgency of the Hazard

Level I Recall: Recall of unsafe food that has caused or may cause severe harm to human health or even death due to food contamination, foodborne illness, etc., or has a wide circulation range and significant social impact.
Level II Recall: Recall of unsafe food that has caused or may cause harm to human health due to food contamination, foodborne illness, etc., with moderate severity or a smaller circulation range and minor social impact.
Level III Recall: Recall of unsafe food that has caused or may cause minor harm to human health due to food contamination, foodborne illness, etc., or contains ingredients that may pose health risks to specific populations without informing customers.

4.4 Confirm Relevant Information for the Batch

Recall reason: Impurities, contaminants, hygiene indicators, physicochemical indicators non-conformance, etc.
Raw milk information: Vehicle plate number, exit inspection results, sample retest results, customer retest results.
Raw milk quantity: The quantity of this batch, the quantity of related raw milk products in stock.
Raw milk sales-related customers.
Determine the current specific location of this batch. (6) After confirming the above information, notify relevant departments and report to the group center.

4.5 Prepare for Shipment

If the batch of raw milk is about to be shipped, immediately stop the shipment, isolate or recall, and wait for processing.

4.6 If the Related Raw Milk of This Batch Has Been Shipped or Is in Transit

When the Quality Control Department confirms information about raw milk safety and quality issues, they jointly make a judgment with relevant production department heads and the group center. If the conditions for raw milk product recall are met, report to the farm manager, establish a recall team, and immediately execute the recall procedure after approval by the farm manager (requiring recall action to begin within 30 minutes of receiving the information to prevent unnecessary harm and loss).
Simultaneously investigate whether there is inventory in the same milk tank as this batch of raw milk and whether other raw milk related to this batch has the same quality and safety issues. If so, store them separately with clear identification and add a “Non-conforming Product” sign.
After confirming the recall, the head of the Milking Department immediately notifies the customer of the main recall information by phone. The Milking Department continuously monitors the recall situation of raw milk products and promptly feeds back information to the farm and relevant group centers. The raw milk recall progress should be communicated with customers via telephone.
Notification letter to customers: The content of the letter includes the customer’s name, address, contact method, raw milk quantity, problem description, and specific explanation of the handling results.

4.7 Post-Recall Handling

After the raw milk is recalled, the head of the Milking Department arranges for unloading into the milk tank while simultaneously cooling and sealing. A “Non-conforming” label is added to the storage tank, and it is stored separately from other raw milk.
The Quality Control Department re-analyzes the recalled raw milk and submits the final test and review results to the farm manager and relevant group centers.
The farm manager and group center comprehensively evaluate and provide final handling opinions, which relevant departments strictly implement.
Before the recalled raw milk is destroyed, its intended use is changed, it is determined to be safe for its original (or other) intended use, or it is reprocessed to ensure safety, it should be done under the supervision of the recall team.
Fill out the raw milk product recall record from the receipt of information to the final handling result after recall, and have it approved by the recall team leader (farm manager) as input for enterprise review.
After the actual recall is completed, the Safety Department reports the handling process and results to the local quality supervision bureau in writing, accepting their supervision.
The Milking Department analyzes the quality issues and causes to the customer, and the Quality Control Department and relevant production departments organize the establishment of corrective measures to prevent similar problems from recurring.

5. Recall Record Management

The responsible department head should accurately record the product recall process information and maintain relevant records. Specific management requirements are implemented according to the “Document and Record Control Procedure.”

6. Recall Communication

6.1 Contact List Requirements

Each farm should establish a contact list of relevant personnel involved in the product recall process to respond to recall events promptly and effectively. The contact list should include at least the Food Safety Team members (leader, deputy leader, Milking Department, Quality Control Department), Quality Assurance Department head, Raw Milk Sales Department head, etc.

6.2 Product Recall Summary

After handling unsafe products, the responsible department should summarize and communicate the product recall work and propose further improvement measures:

Analysis of the causes of problems with recalled products, recall start and end times, specific processes, and regional scope;
Quantity, batch, and disposal of recalled products;
Economic losses incurred;
Recall responsibility definition, handling of internal responsible departments or personnel, and claims against external responsible parties;
Problems encountered during the recall process;
Improvement measures for addressing issues.