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Survival Guide for Handling Food Recalls
by Renata McGuire
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.
Companies should use the templates and forms that worked well during previous mock recall exercises to quickly identify and isolate affected products.
Convey the Message
Communication is one of the most important tenets in crisis management–not only to consumers but to all stakeholders. Company employees, too, share a role in conveying a consistent message about the recall.
Companies should use any type of communication format that will reach their customers. A public notice on a regulatory website may or may not get noticed by their target consumers. Use the media with care because the message a company sends is permanently recorded with today’s technology. Food companies should also contact distributors, retailers, and customers to inform them of the recall, including instructions on how to handle the product.
Another key part of conveying the message is answering all questions. Better yet, anticipate those questions and communicate the information before the questions arise. This not only demonstrates the control a company has over its operation and the crisis situation but also works to reassure and calm stakeholders and, in the process, helps to maintain the company’s reputation.
When a product recall occurs, it is important for a food company to open its doors quickly. The best approach in dealing with this attention is to cooperate with customer and consumer inquiries and, inevitably, with regulatory authorities.
But Is It Working?
Throughout the recall process, checks must be put into place to ensure that the product recall is effective. The returned product is received and counted in order to compare against the amount produced and determine the recovery rate.
Additionally, a decision may have been made to send product to an off-site or third-party warehouse due to space constraints or to better isolate it from other production lots. This inventory should be verified regularly to ensure a correct count and secure location.
Write It Down
Food companies must keep track of all events, decisions, and meetings as they occur. A great deal of information is being exchanged, and many decisions are being made. It may be wise for a company to assign someone to act as a secretary who will take notes of the activities taking place. Not only will this provide information for later review, but it will also enable the recall team to focus on managing the recall crisis.
Here’s a chance for food companies to consider why a recall was required in the first place. Appropriate root cause analysis tools like the “5 Whys” not only help a company maintain continuous improvement, but they also enable a thorough investigation and understanding of the cause of the recall.
Why did a product recall occur?
A consumer found, and then a regulatory official confirmed, that the product contained undeclared milk allergens.
Why did the product contain undeclared milk allergens?
Careful review of the formulation, ingredients, and production records revealed that one of the sub-ingredients contained a milk ingredient, which was not declared on the label.
Why did the label not contain the milk ingredient in its listing?
A new ingredient had recently been approved for use in the product; however, the protocol to review the ingredient contents and label were not followed.
Why were written ingredient approval procedures not followed?
There was a supply shortage of the material and an urgency to use this new ingredient supply, and it was approved directly by senior management.
Why did senior management approve the new supply?
It was important to continue production, and the senior manager who was asked for the material approval was not aware of the current protocol to review allergen content against the label.
Food manufacturers no longer discuss product recalls in if terms; conversations now revolve around when a product recall will occur.
Why was senior management unaware of the ingredient approval procedure and approved supply?
The senior manager charged with approving the material was not included in reviewing the ingredient approval procedure when it was updated and was not included in its distribution.
Food companies must ensure that there are appropriately trained resources available to perform root cause analysis, either on the recall team or available for consultation on short notice. It may be that the issue causing the recall has closed down the facility for investigation, and timing is critical. Using appropriate root cause analysis tools will help to find and resolve the issue much more quickly than a haphazard investigation. We can see from the example provided at left that root cause analysis rarely identifies one single cause of an incident, and it may take more than one action to prevent recurrence.
Testing may be part of finding the root cause of the recall; in preparation for this possibility, ensure that laboratories have been identified to perform testing, whether it be microbiological, toxicological, or foreign material analysis. If a food company does not have in-house expertise to fully interpret lab results, this is the time to call in an expert, and it is usually helpful to have an outside set of eyes assisting in the root cause analysis to identify areas that may have been missed.
Food companies should make time to debrief and review how the crisis was managed—what went well and what didn’t. Written recall procedures should be reviewed and updated to improve or better reflect the recall process. Any corrective actions identified from root cause analysis should be implemented, and team members should verify that they are working effectively.
Renata McGuire is project manager for food safety/resource material at the Guelph Food Technology Centre in Guelph, Ontario, Canada. She is responsible for providing food safety consulting services and for developing, maintaining, and upgrading the resource materials and consulting tools used for GFTC consulting projects. Her background is in toxicology, and she has extensive experience managing vendor audit programs, implementing a variety of HACCP and food safety programs, and managing product testing functions.