Are You Ready For Your Next Food Recall?

By Sam Lewis

Obviously, a recall is one of the last things a food manufacturer or processor wants to endure. Food recalls wreak serious havoc on bottom lines, brand reputation, and consumer confidence; this is why food makers go to such great lengths to prevent them. However, despite the best laid HACCP plans, food security policies, and GMPs, food recalls still happen. If one were to happen to your company today, would you be ready for it?

Food recall plans are created to quickly and effectively locate contaminated, damaged, or out-of-specification food products, remove them from the marketplace, isolate them, destroy them, find the cause of the event, correct the cause the cause of the event, and assure the public of the affected company’s obligation to food safety. Because the recall plan does all of these things, establishing a food recall committee to create a list of procedures and individuals who will execute them is imperative. Below are 12 fundamental elements your company’s food recall plan should include.

1. Intentions
   The first element a food recall committee should take in creating a food recall plan is establishing intentions. The food recall plan should make it clear why such a plan exists and for what particular products. Cleaning and sanitation procedures the company follows for each product can also be included.
    
2. Terms And Definitions
   You should include a section that defines all of the terms related to a recall. Each level — degree to which it will affect public health — of a recall also should be defined. A few examples of these terms include recall, withdrawn from market, recall classification, and class I, II, and III recall.
    
3. Roles And Responsibilities
   Every person in your company who has a role in executing a recall should have their tasks and accountabilities laid out in your company’s food recall plan. The food recall committee will determine each member’s responsibilities. Finally, each member of the committee should have current contact information listed within the recall plan, and this information should be updated immediately when changes occur.
    
4. Data Collection
   Information about contaminated or affected product can be gathered two ways: internally or externally. Internal collection occurs when a product is determined to be contaminated or out of specifications by someone (e.g., plant worker, packager, warehouse employee, or others) within a food company. From there, the severity of the issue needs to be immediately evaluated by plant managers and/or quality assurance managers. If serious enough, the recall team should also be alerted.
   
   Obviously, external collection occurs outside the confines of a food manufacturing facility. Often external data is collected through consumer complaints. Each occurrence should be investigated by appropriate departments to determine the severity of the issue. If the problem is found to be serious, the recall team should be notified immediately.
   
   Additionally, a questionnaire should be included in your company’s recall plan to record details about the affected product. This survey should include questions such as, “What caused the complaint?,” “When did the complaint occur?,” “Have any tests conducted support the complaint?,” and “What are the serial numbers of affected products?”
    
5. Hazard Assessment
   Any potential health hazards the affected products may pose to the public, along with the recall class, should be stated in your food recall plan. This assessment should evaluate if illness or injury has occurred from the affected product, the severity of health hazard the product poses to the public, the short- and long-term health consequences of consuming affected products, and how much of the affected product is on the market.
    
6. Regulatory Body Notification
   Once the decision to execute a recall has been made, the recall coordinator — as determined by the recall committee — must notify regulatory agencies. The contact information of regulating bodies should be included in your recall plan. When notifying the appropriate agency, the recall coordinator should provide all identifying characteristics of the affected product, the reason for recalling the product, how the issue was found, how much of the affected product was made and distributed, all records of distribution, all recall communications, recall depth, and a warning to the public about consuming the affected product. With this information, the regulating agency will determine the depth of the recall.
    
7. Communication
   A successful recall is dependent upon effective and appropriate communication. Public relations members and the recall coordinator should set up a recall communication center and draft documents to communicate with suppliers, retailers, wholesalers, and consumers. Those pre-made documents should include a press release and a communications letter.
   
   The press release should be a generic template that can be modified as-needed. It is used to alert the public of the affected product and any potential health risks it poses. Any class I recall requires a press release, but the FDA will advise companies of any situation that requires a press release and may issue its own.
   
   The communications letter should be drafted and amended as-needed to inform your company’s partners (i.e., suppliers, retailers, and wholesalers) about the recall. Additionally, documents that show which means of communication will be used, i.e. media outlets, wire services, and sample communications, should also be drafted. Finally, within these documents, the name and contact information of a designated spokesperson should be included.
    
8. Status Reports
   Generating these reports intermittently during a recall will give a brief summary of the effectiveness of the recall. Your status reports should include a record of how many suppliers and retailers were notified of the recall, who responded to the notification, and how much of the affected product has been accounted for. The food recall plan should indicate how often these reports are to be generated.
    
9. Returned Products
   Your recall plan should clearly define the company’s strategy for handling the returned product. Create documents stating that returned products will be isolated until the recall has ended, isolated products will be destroyed upon approval from management, and that you have notified the FDA of your plan to dispose of affected products.
    
10. Ending The Recall
    Within your recall plan should be policies stating how to end the recall process. Include written statements declaring that the recall coordinator will decide when the recall will end and when consumers will be issued replacement products or reimbursed. Returned products should be controlled by the plant that produced them, and the total number of returned products must be reported by the plant’s QA manager.
    
    Your company’s recall coordinator will create documents reporting the entire recall for management. The reason for the recall, its extent, how much affected product was recovered, how returned products were handled, and the total cost of the recall should be included in this report.
     
11. Supplements
    Your recall plan should include all the drafted, generic documents your company will need to successfully endure a recall. Included in these supplements are definitions of recall classes, a press release template, a sample FDA press release, a template to create a product withdrawal form, and a recall flow sheet outlining how information is passed along and how decisions are made in the recall process.
     
12. Mock Recalls
    When all of these documents, policies, and procedures have been established, mock recalls can be performed at your facility to determine the plan’s overall efficiency and any failures within it. Should a mock recall reveal major flaws in your recall plan, third-party organizations can offer assistance in establishing robust, tried-and-true procedures to help strengthen your company’s plan. Hiring a consultant to help you overcome this challenge may seem like an excessive expense, but, I assure you, the cost of this advice is significantly less than the cost of a lengthy recall.