Purpose:

To implement a policy on recall, withdrawal, stop sales and impounding. This policy is to ensure that when these actions are warranted, implementation will be accomplished with maximum concern for public welfare. These actions will be completed as quickly and effectively as possible and with minimum consequences to the Corporation or the public.

Application:

This policy will govern all products shipped by United Commodity Group, Inc.

Definitions:

1. Significantly Defective - Include any serious defect, which renders the product unacceptable or unsatisfactory performance.
2. Seriously Defective - Defects rendering the product subject to recall types Class I, II, or III.
3. Recall - Class I - The most serious type of emergency involving the removal of the product from the market in which the consequences are immediate or long-range, life threatening and involve a direct relationship. This is accompanied by widespread publicity, both governmental and private, to remove the product from all market channels and households.
4. Recall - Class II - A less clear-cut, but still serious or potentially serious situation, in which the consequences may be immediate or long-range and possibly or potentially life threatening or hazardous to health. Since the hazard is less clear or somewhat more remote, this involves removal of product from distribution channels, including retail market, but not the home.
5. Recall - Class III - A serious violation which renders a product substantially adulterate, badly mislabeled or clearly non-saleable or unsatisfactory. The health hazard is nonexistent or remote. Recall from homes would be very unlikely; recall from stores more possible, and from warehouse is a certainty. 
6. Withdrawal - Recovery of product from the end user and distributor warehouses.
7. Stop Sale - Cessation of shipments until acceptable product is available. 
8. Impounding - In-house action to have movement of a suspect or defective product stopped until proper disposition can be determined.  

Procedure:

All products must be manufactured in compliance with good manufacturing practices and meet quality standards so that no defective products reach the market. If in spite of all efforts, if defective products reach the market, the following procedures will apply:

1.  Prepared Foods Recall Committee Composition
     A. Senior VP
     B. Accounting Manager
     C. Warehouse Manager

2.  Committee Responsibilities  
     A. Establish such general guidlines or procedures for its

         operation as shall be sufficient to ensure that.

         I.  All available information is applied.

         II.  Consider all available information and formulate and

              make decisions dealing with:

               a. Retrieval of affected product outside company

                   controlled.

               b. Disposition of affected products still within

                   company controlled.

               c. Notification of regulatory agency if that appears

                   necessary or desirable and the agency is no yet

                   involved.  

               d.  Statements for public or internal distribution.

     B. Direct the assembly of all information needed for

         decisions respecting a recall or withdrawal. 

3.  Checklist: A partial checklist of probate or potentially useful

     information including:  

     A.   The specific nature of the problem 

     B.  Exactly how, when, where and by whom the problem

           was identified.

     C.  The certainty and seriousness of the problem. 

     D.  The particular products affected. 

     E.  The location, quantity, dollar value, and control of all

          affected or potentially affected products. 

     F.  The names, addresses and phone numbers of all

          possible product locations or consignees. 

     G.  Current solid evidence supporting A, C, D, E and F and

           the time required obtaining conclusive information with

           respect to these. 

     H. Outstanding warehouses, not regularly used, where

         recalled or withdrawn production can be safely held

         awaiting disposition.

4.  Communications - Regulatory Agency - Company initiation

     of regulatory agency contracts shall be through the recall

     committee.

Recall Procedures

1. Complaint is received which classifies as a Class I, II or III Recall.
2. A member of the recall committee will assemble other members of the recall committee.
3. Sales and administrative personnel will gather inventory sheets, order forms and manifest sheets for affected dates of productions.
4. The customer recall contact will be notified of the recall.
5. The recall committee will track the affected product to the first customer; dates of shipment and arrival are determined.
6. Sales personnel will notify the customers of the problem and will give the customer all pertinent information. The customer will be responsible for gathering, isolating and tagging all affected products at their location.
7. The transportation department will arrange transportation of affected product back to the warehouse.
8. If the customer does not call to verify that product has been located, isolated and tagged, sales personnel will contact them and report back to the recall committee.
9. Product is returned to the warehouse.
10. The recall committee will assemble once again to determine disposition; the primary administrator will assure that the disposition process is properly handled.
11. A follow-up to the customer recall contact will be performed once a resolution has been determined.