(Editor’s Note: This is an online-only article attributed to the October/November 2018 issue.)
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Bad news travels faster than a Salmonella outbreak on the 4th of July. That’s why when a food safety crisis hits, or any situation that challenges the safety or quality of your product, it’s essential to respond immediately. And that response should emphasize both what you’re doing about it and how you will communicate what you’re doing.
Imagine the following scenario from the viewpoint of a food safety professional: It’s 3 p.m. on the Friday of a long holiday weekend. The manager of your food facility is on the road, and you’re on the phone with the local health department. They’ve just informed you that your nationally distributed product has been linked to a Salmonella outbreak—and the Department of Health wants to know what you’ve already done about it.
What else can go wrong? Lots. A few real-life examples:
- The suspect ingredient, which is obtained from multiple sources, was identified—but there’s no way to match the supplier with the batch/lot.
- The product is manufactured by another company that doesn’t agree with your decision to recall everything. It wants to limit the recall to the known problem lots but cannot say for sure why there is a problem in the first place; it can’t even assure that there won’t be more lots with more problems next week, or next year. And, they plan to sue for payment on the lots made—even those for which you refused delivery.
- You are forced to recall the same product for the third time for the same problem: a resident population of a pathogen that you can’t seem to eliminate. The FDA has asked to stop all manufacturing, sign a consent decree of permanent injunction, and resume only when the agency says you can.
What Do You Do?
The same question applies in all these cases: What do you do now? The below tips can help.
Follow your recall plan. Unless you can unequivocally rule out your product as the problem, assess the information linking your product to the reported problem and initiate a recall. While the FDA and other food safety authorities could be wrong, they very rarely are.
Do not hesitate. If the problem is defined by FDA as Class 1, with the likelihood of injury or death, speed is crucial. You might literally be saving lives by moving quickly to remove suspect product.
Make it official. File a Reportable Food Registry report on FDA’s website within 24 hours of learning of the problem associated with the product. You probably won’t have complete information, but the regulation does not allow you to delay reporting until you have everything. The file updates as more information is available.
Advise legal, don’t wait for legal advice. Inform those in the company who need to know, including the legal representative. Do not ask the attorney if the product needs to be recalled; that is a decision management must make. The FDA will hold management responsible, as will third-party attorneys who are representing injured consumers.
Communicate early and often. It’s important to acknowledge the issue publicly and to state what the company is doing to research and resolve the issue. Take an empathetic tone and resist the urge to become defensive. Many crises are inflamed by leaders taking issue with media reports.
Strike the right chords. Companies should always be honest and forthcoming and speak with compassion when discussing the crisis publicly. Websites and microsites should be updated in real time to keep employees, key stakeholders, and consumers informed. If possible, post a short video featuring a relatable spokesperson within hours of the issue going public.