Food product recalls are on the rise, and so is media, regulatory, and public scrutiny of these events. A recall is a crisis situation that needs to be managed well to satisfy regulators and the court of public opinion. There are lessons to be learned from recent recalls, and this quick survival guide outlines a few. They are organized around recall steps:
- Advance planning,
- Evaluation, and
Plan for It
Food manufacturers no longer discuss product recalls in if terms; conversations now revolve around when a product recall will occur. The food industry is full of fresh examples of large, successful food companies with mature food safety systems managing their recalls in the news. Planning for a recall is a prerequisite to a sound food safety program and just good business practice.
A food company’s recall procedure should be in writing, clear, realistic, communicated, and practiced. Practice is achieved through mock recalls, which are dress rehearsals for the real deal and offer an opportunity to work out kinks and increase speed. The procedure needs to define the composition of the recall team, which will carry out the critical recall function. The recall team must have a strong coordinator, and this role is not necessarily assigned to QA or QC. This team must have representation for key functions of the recall: shipping/receiving, customer service, and logistics—as well as at least one member of senior management. The entire recall team should be involved in mock recall activities; these not only act as exercises in traceability but also serve as reminders and practice for the role of each recall team member. Contact information for each recall team member must include both work and off-hour phone numbers. The entire recall procedure, including contact information, needs to be updated at least annually or as changes occur.
Should We Recall?
When food companies reach this point, the discussion should be about the risks related to a product issue. The original discussion may have been initiated through regulatory channels, customer complaints, or internal findings, but now discussions are often concerned with the financial cost, regulatory compliance, and reputation associated with recalling a product. A recall program should have predetermined criteria that has been established, specific to a company’s product, and how a decision to recall will be decided, including a reference to regulatory requirements. For example, recall criteria could include pathogen limits, evidence of foreign material contamination, and failure of allergen controls, among other criteria.
In Canada, when the product concern involves a risk to consumer health or safety, the Canadian Food Inspection Agency must be consulted to ensure that the decision is the correct one. By including criteria for recall in the written program, food companies can help the team to focus during a time of crisis.
However the conversation began, ending with a decision to initiate a recall opens a new chapter and, for many food companies, involves a trip into unchartered waters. Although the question of why or how a company may have found itself in this situation is overwhelming, it will be answered in due process and should not be considered at this point. Steps must now be taken to identify all products that will be recalled and to hold and segregate those products.
Regulations and regulators are demanding more expedient recall processes. As a consequence, many of our clients have moved their standards for full traceability from four to two hours—including real time in some cases. To achieve those times, the recall team needs to be assembled quickly and must know the written procedures as well as their vacation schedules. Those written procedures should be the starting point for their planning and activities. In a crisis situation, it is far too easy to act on instinct, forgetting about documented policies and instructions—policies and instructions that were carefully crafted to protect the company and its customers.