Bombay SapphireIt has been sunny and warmer here in Seattle for the past couple of days – a welcome respite from the prior 175 consecutive days in which when our temperature never reached 70 degrees.  And with the sun one’s thoughts naturally turn to the cocktails of summer – starting of course with the classic gin & tonic.

I enjoy the occasional G&T, but candidly sometimes believe they’re just a bit too weak.  And that’s why I’m thinking of driving up to Canada to see if I can get my hands on some Bombay Sapphire gin.

What’s that you say? Bombay Sapphire is available essentially everywhere – so why would I go to Canada for mine?  Well, this is a very special bottle.  You see, the Canadian Food Inspection Agency has just announced that something went awry in a recent bottling of Bombay Sapphire, and up to 6,000 of their 1.1 liter bottles have a bit higher alcohol content then usual.  How much higher?  Almost twice as much, actually.  Normal Bombay Sapphire is bottled at 40% ABV – but these are testing out at 77% ABV.   Yep, you read that right.  This is 154 proof gin.  That would make for a very interesting G&T.

In all seriousness, the Canadian health authorities are concerned that these bottles may pose a health risk – though there are no reports of anyone becoming sick so far – and the product is being recalled.  According to Bacardi – the owner of the Bombay Sapphire brand – the mixup happened when “over proof product inadvertently entered the bottling line during a short period of time” when workers “were switching from one bottling tank to another bottling tank.”

All this serves to remind producers of the importance of maintaining not only control over your production methods (including bottling) but also the importance of keeping good records.  Here in the U.S., should you ever be in the unfortunate position of needing to recall product from the market you need to be able to quickly identify where you’ve sent that product (and to be able to identify it with some certainty).  In addition, you need to be able to quickly identify the vendors whose inputs were incorporated into the product (e.g., raw materials, bottles, closures, etc.).  In both cases, applicable law expects that you can accomplish these tasks within 24 hours of learning of tainted product.  Under the Bioterrorism Preparedness and Response Act of 2002, the Food and Drug Administration imposes these record-keeping requirements on all “food handlers.” For purposes of the Act, distillers (as well as bottlers who do not themselves distill) are within the “food handler” definition.

In addition, be mindful of the need to move quickly to determine the true nature of the problem with the product.  Does your Hooch simply have an incorrect label? You may – after discussion with the TTB – be able to allow existing stock to be used up without having to conduct a recall.  But if the product creates a health and safety hazard, or worse yet a substantial threat of death or serious health consequences, then you should expect that you will be pulling back the product.

If you do need to pull back the product, note that tracking and record-keeping again become very important.  You need to keep track of what product you’ve taken back during the recall and keep track of the product that you (or your agent) remediate or destroy as part of the recall.

Make no mistake, no company wants to be faced with a product recall – and keeping these records can feel like a significant administrative burden without much benefit. But if you are faced with a Bombay Sapphire-type problem (can we call that a BS problem yet?), then having taken these steps will give you the best chance of surviving the storm.

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