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The recall process is a way for consumers to hold suppliers accountable for the products they produce .
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Additionally , the federal government has made changes to the information it is providing to Canadians with the goal to improve transparency about recalls . It is now official government policy to post all recalls , regardless of public health risks , on cannabis for medical purposes to the department ’ s online recall database . It will also continue to publish annual and quarterly compliance and enforcement reports with information about medical cannabis recalls and other compliance and enforcement actions undertaken by the department . At the time this article was written , the recall database on Health Canada ’ s website shows nine recalls of cannabis products since November 2016 . Three of the recalls were related to labelling issues of products , and the remainder of the recalls were due to detection of pesticides . Taking a step back , the recall process is a way for consumers to hold suppliers accountable for the products they produce . When customers feel that a product does not measure up to the promise the producer made , they can contact them about their concerns . If customers experience negative side effects that they believe are related to the product , they can contact the supplier and , in Canada , they can also contact the Canadian Vigilance Program . A recall process is initiated when a complaint comes in , either to the producer themselves or through Health Canada . Typically , there are three types of complaints that would start a recall process :
• Patient – This usually comes in the form of “ I am a customer , and I have a problem …”
• Health Canada – This can be through the vigilance program reporting or related to random testing that Health Canada conducts . It can come in the form of “ We have identified a problem …”
• Trade Complaint – This type of complaint is more common than you might expect and happens when a company takes a closer look at a competitor ’ s product and files a complaint with Health Canada based on label claims . It often also takes the form of “ I have a problem …”
Once a producer initiates a recall process , a number of things begin to happen all at the same time . This is the moment where everyone stops eating , stops sleeping , and the stress meter maxes out . This is a big deal , and everyone understands that every minute matters and every detail is important . The quality assurance person is the point person for a recall , but in most cases , the big items are split between teams so that all the details are not piled on one desk . One team begins to collect the details of the recall and contacts Health Canada . The goal is to deliver the recall message , including details about what to do with recalled products , to affected patients . After the patients are contacted , Health Canada posts a public notice about the recall , including information on the company and the specific products , on its website . Health Canada has three categories of risk for product recalls , and each recall is assessed and categorized before the initial patient contact occurs . Type I is a situation in which there is a reasonable probability that the use of , or exposure to , a product will cause serious adverse health consequences or death . Type II is a situation in which the use of , or exposure to , a product may cause temporary adverse health consequences or where the probability of serious adverse health consequences is remote . Type I and II also include situations where a product that does not have generally recognized or supported therapeutic value is promoted in such a way that avoidance of recognized therapy occurs and where such avoidance could lead to injury or death . Finally , Type III is a situation in which the use of , or exposure to , a product is not likely to cause any adverse health consequences . At the same time the first team is working with Health Canada , another team begins an investigation about the recall . The task is to determine what happened . Each organization approaches this differently but essentially , each want to answer some key questions :
• How did this happen ?
• Where did the problem come from ?
• What other products are affected ?
• How do we fix the current problem ?
• How do we avoid repeating this problem in the future ?
This last question is where our job in the testing lab can kick into high gear again , as an investigation often raises some interesting questions about the process a client has used . We can be asked to provide support testing to answer the questions that come from an investigation .
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