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Rapid Recall Exchange a Vital Tool in Recall Management for the Food Industry
by Neil Canavan
In managing any crisis situation, it is critical that all available resources be brought to bear. This is particularly true in the food industry, where a product recall may be addressing an eminent threat to human health. For greatest efficacy, a recall management plan must enable a rapid and comprehensive response; however, cobbling together such a plan has become increasingly burdensome as food products—and the sources of those products—continue to diversify. These are the drivers behind the advent of the Rapid Recall Exchange (RRE).
Launched in late 2009, the RRE—developed by the Food Marketing Institute and GS1 US and supported by the Grocery Manufacturers Association and the National Grocers Association—is an online service that is designed to accelerate food product recalls and withdrawals. The functionality of the service is a direct result of input from industry stakeholders.
“Starting around 2007, our members started asking that we step up our involvement as it relates to recalls,” said Brian Lynch, senior director of business and industry development at GMA. To gain a greater understanding of the particular nature of their member’s concerns, the GMA conducted a number of surveys, with responses from retailers and manufacturers alike, resulting in a consensus of the problem. “They specifically asked for our help in streamlining and making the recall process more efficient,” said Lynch.
GMA members reported that the increasingly complex supply chain was needlessly draining time and money. In 2009, for example, in testimony before the House Small Business Subcommittee on Regulations and Healthcare, Mike Ambrosio, vice president of quality assurance for the Wakefern Food Corp., said that in the last fiscal year prior to his testimony, Wakefern experienced 214 recalls, including 27 Class 1 recalls and 43 pharmacy recalls, encompassing 218 stock-keeping units (UPC codes). “The process took an average of 10 hours per product recalled,” he said, racking up a grand total of 2,140 expensive hours of labor.
The Birth of the Rapid Recall Exchange
In brief, the RRE is a web-based portal for the exchange of information between food retailers and manufacturers that is designed to elicit specific, comprehensive information from a supplier regarding a given product for recall—information that is then rapidly disseminated to any and all recall stakeholders. Communication between stakeholders is standardized, and the receipt of information is verifiable.
All aspects of the program are designed to meet the specific needs of the user. “In Class I situations, the way the system is set up is as a shotgun approach—a mass e-mail,” explained Lynch. “For Class II and III situations, [RRE] functionality allows initiators and manufacturers to select the specific trading partners that are known to have received a defective product.”
The RRE offers a robust way of satisfying the FDA’s required effectiveness checks. By verifying that an authorized recipient has opened an e-mail alert or has checked the system, the portal assures the recalling organization that the retailer has been notified.
One of the impediments to effectively populating RRE’s database of industry contacts is determining just who exactly, within a given company, needs to be notified. “In the user authentication process, there is a big challenge to ensuring that [an RRE subscriber] has the right contact within each trading partner company to reach out to,” he said. Further, not only does it have to be the right person, but it also has to be the right person’s correct e-mail and current phone number.
All of this ties into a key facet of RRE: the ability to verify. Speaking to this point, Hilary Thesmar, PhD, vice president of food safety programs at the Food Marketing Institute, said, “With an e-mail or with a phone call, it’s difficult to verify that a message was actually received. What this portal does is that when that e-mail is opened, or when the system is checked, there is a message sent back to the supplier saying that this specific person at the company read the message, so there’s a record that the message was received, and that counts as verification.” This component of the RRE is a robust way of satisfying the FDA’s required effectiveness checks.
“We presented the program to the FDA, and they are very pleased with it,” said Dr. Thesmar. “They were impressed that industry took the initiative to go above and beyond what the regulatory standards are, to solve a problem, to exceed regulatory expectations, and to do so in a way that is even faster than even the FDA was expecting.”
The comprehensive nature of the message received is again facilitated by RRE’s design. “There are a lot of drop-down menus in the portal. It reminds you of all the information that you need to enter,” said Dr. Thesmar. Great care went into accounting for the appropriate data fields that the FDA and USDA require, including production dates, lot numbers, pictures, stores the product went to—the entire distribution pattern.
‘I can tell you that the retailers who use it...like it because the information is presented in a consistent format, and they’re getting everything they need to initiate a recall. Suppliers that use it like it because it gives them a consistent way to enter all this information.’
Food Marketing Institute
Instructions for reimbursement are also prompted by the system. “Once you‘re familiar with the portal and how to enter information,” said Dr. Thesmar, “it is a very consistent and very easy-to-use tool.”
There are redundancies with existing protocols, of course—recalls are not new. “Rapid Recall Exchange is the gold standard, but not everyone uses it,” Dr. Thesmar conceded. “But I can tell you that the retailers who use it … like it because the information is presented in a consistent format, and they’re getting everything they need to initiate a recall. Suppliers that use it like it because it gives them a consistent way to enter all this information.”
The system is also dynamic. “It’s not an all-or-nothing process,” explained Dr. Thesmar. “They can enter some information, and then as the situation evolves, go back and enter more information later. Let’s face it, a recall is a crisis situation. By nature, it’s chaotic. You don’t always have everything you need right away.”
Adoption = Efficacy with RRE
The utility of the RRE relies on casting the widest possible net, and the efforts to expand that net are ongoing. “We continue to focus on increasing the usage among the retailers that are not yet using it, as well as some of the suppliers,” said Dr. Thesmar.
With the enthusiasm expressed by current users, universal adoption of the program shouldn’t be too far off: Shortly after the rollout of RRE, Mike Ambrosio of Wakefern Food Corporation issued an edict requiring all Wakefern vendors to sign up for the RRE.
Neil Canavan is a freelance writer based in Brooklyn, N.Y. Reach him at firstname.lastname@example.org.