4.0.
4.1 Recall Strategy Where there is an impending voluntary recall, the Manufacturers, wholesaler, Pharmaceutical retailer, Marketing authorisation holder, local responsible person, Importers and Distributors shall submit to the Authority a proposed strategy to facilitate implementation of the recall strategy in respect of the particular recall. The recall strategy shall be in line with the Standard Operating Procedure on Recall of Medical Products and the following factors: a) Description of problem; b) Number of complaints; c) distribution networks; d) recovery procedures; and e) resources for corrective action. The recall shall be completed by the date as directed by the Authority. However, in the case of unforeseeable delay, the marketing authorization holder, local responsible person, or distributor shall notify the Authority of factors which may affect the duration of the recall action. The Authority shall require information for the proposed recall strategy by the Marketing authorization holder, local responsible person, distributor, or manufacturer. The proposed recall strategy shall be agreed upon before implementation and the agreement shall be reached within 24hrs of submission of Pharmaceutical Product Reporting Form and Recall Notification Form. In the recall strategy, the applicant should mention the following: a) indicate the proposed level in the distribution chain to which the recall is extending. If the recall only extends to the wholesale level, the rationale of not recalling to retail level should be explained; b) in case of consumer level recall, additional information should include location of recall distribution channels for consumers; c) indicate how the message of recall will be delivered to customers e.g. press release or recall letters etc.; d) If the Marketing Authorisation Holder, local responsible person, distributor and/or manufacturer has a website, it shall promptly post the recall notification on it as an additional method of recall notification; e) Report on what the customers have been instructed to do with the recalled product. It is important for the recalling establishment to know the name and title of the recall contact person for each consignee in order to expedite the communication process during the recall; f) The criteria for returning the affected products must be clearly explained; g) Provide a proposed disposal plan of the recalled products i.e. how the recalled product will be destroyed, reconditioned or returned to the external or local manufacturer; and h) The disposal of the recalled product shall be done in accordance with guidelines on disposal of pharmaceutical waste. Suffice to mention that the Manufacturers, wholesaler, Pharmaceutical retailer, Marketing authorisation holder, local responsible person, Importers and Distributors shall inform the Authority and Zambia Environmental Management Agency before product destruction. The proposed method of destruction shall be approved by the Authority who shall witness the destruction. A Certificate of Disposal shall be issued by the Authority after destruction of the product. 5.0 COMMUNICATION 5.1 Notice of Recall A notice for a statutory recall shall be issued and implemented in line with Section 46 of the Act. In case of a voluntary recall, the Marketing Authorisation Holder, local responsible person, distributor or manufacturer shall prepare and submit a notice of recall with a factual statement of the reasons for the recall of the product, together with specific details that will allow the product to be easily identified to the Authority for approval before publication. The notice of recall submitted to the Authority shall not contain any material that can be viewed as promotional in nature. The Authority may also issue a notice of recall in addition to the notice of recall from the Marketing Authorisation Holder, local responsible person, distributor or manufacturer. For retail level recall, the Marketing Authorization Holder, local responsible person, distributor and/or manufacturer should have confirmation for returning all the stock on hand from the consignees. If safety to the public is involved and distribution is limited, the MAH, LRP or distributor may contact the clients of the information listed above by telephone and followed by a recall letter. The letter should be retained for a period of not less than three (3) months to ensure that any products still in transit or on its way to retail or hospital is adequately managed and quarantined. 5.2 Media Release (Public Warning) In the case of a recall, where a media release is indicated, the MAH/LRP/distributor and the Authority shall draft the text of the media release with the assistance of expert advice where necessary. In the case of a Class I or customer level recall the text of the media release shall be developed by the MAH/distributor, in consultation with the Authority. The media release should contain sufficient and relevant detail to uniquely define the product, together with a clear outline of the problem (without causing unnecessary alarm) and must state the appropriate response by the consumer, client or user. A 24-hour access telephone number of the MAH/distributor should be given for further information. In considering the media release by the marketing authorisation holder, local responsible person or distributor, the Authority shall approve the choice of media with the widest coverage. 5.2.1 Content of the media release The recommended content of a media release shall: a) be signed by the Responsible Pharmacist or authorised person; b) have a heading indicating “Urgent Medicine/Allied Substance Recall”; c) indicate the Classification and level of the recall; d) have the name of product, dosage form, strength, marketing authorisation Number, pack size, batch number(s), expiry date and any other relevant information necessary to allow for absolute identification, where applicable; e) have a brief description of the nature of the defect; f) have urgency of the action; g) have reasons for the action or recall; h) have an indication of a health risk (this should also state exactly what the product may do if taken, i.e. side-effects); i) provide specific information on what should be done in respect of the recalled medicine/allied substance. Method of recovery or product collection, which will be used; j) have a contact telephone number and an email; and k) have a request to retain the media release in a prominent position for 7 days in case stock is in transit, where applicable.