In part 2 of our series we discussed how a food recall can be devastating, even for a company not responsible for the outbreak of foodborne illness. All the more reason manufacturers, suppliers, distributors, and retailers must take measures to effectively mitigate the risk, and if a recall is inescapable, to manage the process as effectively as possible.
In the unfortunate event of a recall, response time is critical. Each organization along the food supply chain must react immediately according to the best practices of recall management. Since there can be no question about the correct course of action, that means already having a recall plan in place as part of established food safety management system (FSMS). Only an FSMS can make a recall as painless as possible.
Once a food recall has been initiated, it’s the responsibility of all relevant parties to remove the product from the supply chain and reduce the threat of harm to the public. First and foremost, this means activating a recall plan already in place, or developing one in consultation with federal agencies and expert consultants.
The stakeholders in food recalls. Source: https://www.gs1india.org/content/product-recall
Ideally every food company should have a recall plan as part of an FSMS. At minimum, the plan should cover procedures for submitting information to the FDA/FSIS, notifying the public, removing contaminated product from the supply chain, and evaluating the recall’s impact.
Once a recall is initiated, the recalling company submits a recall strategy for review by the appropriate federal agency. This strategy must identify all of the parties along the supply chain implicated by the recall, proposed effectiveness checks, and content to be included in press releases issued to consumers. If FDA or FSIS finds issues that need correcting, they will prompt the recalling company to make those changes.
Along with a recall strategy, the recalling company must also submit a report to FDA/FSIS containing the following data.
The primary reason for the recall:
Once the recall information has been submitted to the federal government and the recall plan has been established, the company must then notify all affected parties. Typically, notification occurs through press releases, recall notification letters and emails to consumers and facilities, company website updates, and social media posts. Recall communications must identify and describe the problem as well as explain the depth to which the recall has been implemented (whether it is retail, wholesale, or user level).
From the outset, company spokespersons must keep customers informed if they hope to preserve their loyalty. The public expects a transparent explanation of the situation – NOT SPIN CONTROL – as well as the option to get their questions answered quickly and accurately. The best way to create a two-way channel from your organization to the public is through a dedicated recall website that offers the latest information and an email address or toll-free phone number specifically for customer questions and concerns. The website, as well as direct mail or phone calls, should also include detailed product return instructions if appropriate. Most companies direct consumers to return defective products to the store of purchase for a full refund or exchange.
If the product must be returned, the company should include exactly how it will conduct this process in the recall strategy submitted to the FDA/FSIS and in communications to all parties along the supply chain and all retail customers.
Equally important, the recall plan must include a trace back strategy. Traceability is key, because regulations require retrieval of all defective products within 30 days. Automated systems work best to organize, track, and document returns in greatest detail, including the quantity and disposition of the products.
Once the public has been notified and the recall has been initiated, the organization should conduct an ongoing recall evaluation to benchmark the recall’s effectiveness.
Regular status reports include:
This information is sent to the local FDA/FSIS district recall manager, along with any corrective actions that have been established, until the recall is officially terminated by the appropriate federal authorities.
Given the obvious financial and time costs this process entails, preventing a recall is clearly better than waiting to respond to one. In fact, since most FDA recall reports read like a laundry list of what not to do, it becomes obvious that the best practices for prevention are equivalent to implementing and maintaining an effective FSMS.
In the vast majority of recalls, FDA and FSIS investigators are able to quickly spot numerous code violations that led to contamination. The most common are:
All of these common causes of a recall are operational errors that can be best be avoided by setting the highest global safety standards (such as those outlined by ISO 22000) and adhering to them. By proactively incorporating safety and quality into food manufacturing and distribution, an FSMS doesn’t merely react to outbreaks – it lowers the overall recall risk before they happen.
Automating the recall management process also helps mitigate the chance of human error while ensuring efficient task completion. Digital tools used within the recalling company can coordinate with external systems along the supply chain to better uncover gaps, as well as create visibility from one operational area to the next.
Adopting strict food safety standards and automated recall management procedures will result in a total system for mitigating recall risk. True, an FSMS cannot guarantee that a recall will never occur, but even if one does, employing FSMS best practices will make the recall process much more streamlined.
A functioning FSMS is also the best defense in case of a lawsuit. According to legal experts, a defendant with documented evidence of safe food handling practices during daily operations is more likely to be found to have exercised “reasonable care” than companies that don't.
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