Unfinished Business: Answering Your Questions About Food Manufacturer/Food Retailer Recall Teamwork

By Sam Lewis

Food Online hosted a live web chat, Food For Thought: Improving Food Manufacturer & Retailer Teamwork In A Recall featuring Alicia Sims-Miller, manager of the reverse logistics and business integration teams for PepsiCo’s North American Nutrition Division, and Kim Combs, recall/regulatory compliance manager for The Kroger Co. In this 45-minute live Q&A, Combs and Sims-Miller answered the audience’s questions about the food manufacturer/food retailer relationship during recalls. While the session was educational and informative, there wasn’t enough time to answer every question. Here, Combs addresses some of the unanswered questions from the live web chat.

Food Online: Miriam is asking, “We have all had recalls. During the investigative process, at what point do you feel enough information is on hand to warrant a recall and have the 24 hour FDA notification clock start ticking?”

Combs: Each recall situation is obviously unique. Being organized and prepared to handle recall situations will help to more clearly define the steps that need to be taken.

Food Online: Greg is asking, “Can you discuss essential data points and information you must have before your team may/can begin addressing the recall and its implications?”

Combs: The main pieces of information often required to issue a recall include: recalling firm, consumer & case UPCs, code dates and/or lot codes, distribution information, reason for recall, and disposition instructions. It is helpful for the recalling firm to share their recommendation on recall classification, as well as photos of the product.

Food Online: Cathy is asking, “The FDA will ask a manufacturer for a list of 'non-responsive' retailers and audit these retailers for recall actions. What is the best method for manufacturers to get recall quantities of destroyed product from retailers to report back to the FDA?”

Combs: This process would vary by retailer, but I expect all should have this information easily accessible. You should try to determine who the Recall Coordinator/Manager is for the issuing retail firm.

Food Online: Julie is asking, ““What are the biggest opportunities within the voluntary product withdrawal/retrieval process, and how can manufacturers improve in this area?”

Combs: One of the biggest opportunities within the retrieval process is to provide accurate information that is retailer-specific. It is advantageous to reach out to retailers ahead of a recall or withdrawal event to understand the expectations and ensure communication is being directed to the correct individuals within the company.

Food Online: Christopher is asking, “Are there any applications where packaging can help reduce the burden of a food recall? If so, what are they and how can they be adopted?”

Combs: Packaging that is developed with locations for code dates to be clearly printed allows for more efficient recall execution at store level. Often times, the code date is printed in an obscure location on the package or is in a part of the package that has a seam and may be difficult to read.

Food Online: Joe is asking, “What is the level of granularity (i.e. lot size) that you can perform a recall against? BIUB date, production line and time range, etc.?”

Combs: The level of granularity will vary by retailer and/or severity of the recall. That being said, it is difficult to conduct a recall down to the specific time-stamp range, especially in the event of a Class I recall. Customer perception must be considered regarding all recall events.

Food Online: Miguel is asking, “How might I assemble a quick recall response protocol and team?”

Combs: A team should be assembled taking into account regulatory guidance. For FDA regulated products, the” FDA 101: Product Recalls” may be a good reference.

Food Online: Elliot is asking, “How involved are your packaging suppliers and their quality systems in a potential recall?”

Combs: The involvement of packaging suppliers during a recall situation varies by product type.

Food Online: Larry is asking, “Why not call them traces rather than mock recalls?”

Combs: There is more to executing a recall than simply tracing the product. Mock recalls should also consider the communication necessary to all parties affected by the recall, and making sure the appropriate individuals are identified and accessible in a recall situation.

Food Online: Uros is asking, “Which practical recall questions should retailer ask himself with regarding the possible scope of a recall?”

Combs: Two of the first questions that should be asked are, “Is there risk to consumers (food safety)?” and “Is there risk to my brand (food quality)?”