Whether you are at home or in the office, accidents and mistakes happen. We do our best to minimize them and set precautions and plans in place for when they arise, but even the best planning and preventive efforts won’t keep them from happening.
For the food and beverage industry, companies remain vulnerable to accidental contaminations and other serious issues that lead to product recalls. A food recall is a voluntary or mandatory action of removing a product from retail or distribution.
The primary objectives in a food recall are to:
- Eliminate potential illnesses, contaminations, deaths, or injuries
- Effectively communicate and coordinate with appropriate agencies, internal teams, and consumers
- Reduce economic loss
- Restore consumer confidence
The Food and Drug Administration (FDA) and The U.S. Department of Agriculture (USDA) have the authority to issue a mandatory recall on any company that produces or sells consumable products. USDA has made it a mandate for companies to have recall protocols in place, and most recently, the Food Safety Modernization Act (FSMA) that was signed into law back in 2011 gave the FDA mandatory recall authority.
Having a recall plan in place is one component of risk reduction. If a recall takes place, traceability and recall plans and actions are implemented to trace products through supply and distributions to stop and spread the potential hazardous food productions or medications in a timely manner and remove them from the marketplace.
The goal of this guide is to provide information to help SMBs in the food and beverage industry mitigate risks and minimize losses. If a disaster happens, you want to be trained and prepared to take on the problem to help return to normal production.
It should be noted that the FDA and USDA categorize recalls into three classes. We will specifically be going into how the FDA recalls a product and how they classify it based on relative health risks. To learn more about how USDA defines their recall classes, The County of Los Angeles Public Health website provides some good examples of how the USDA and FDA classify recalls.
Before a food crisis happens, companies in the food and beverage industry should prepare and craft a detailed recall plan that lays out the steps necessary to conduct the recall and mitigate economic loss.
According to Thomas Rueters Corporation, a recall plan should specifically do the following:
- Identify team members responsible for undertaking each critical task
- Involve legal counsel for all relevant aspects of the recall, including regulatory and insurance elements of the recall
- Utilize key consultants that include a public relations firm to assist in reputation management during and following a recall
- Prepare for customers’ response to the recall and provide a way for customers to submit feedback and questions
- Contain plans to mitigate any business interruptions or supply chain disruptions.
These are just a few details that go into a well-constructed recall plan for a company in the event of contamination. Below we will go into some steps that can be followed to develop a useful recall plan.
When learning of a contamination event taking place, some companies will issue a recall for all products associated with the foodborne illness. While it is normal to react this way, maybe a better response could be focusing on localizing the problem and addressing its sources, thereby minimizing the financial and operational impact.
Pulling the wrong products from shelves can result in a loss of business and create a sense of panic in your consumers. When evaluating the scope of a recall, some questions that you can ask are:
- What is the specific element that caused the product hazard?
- What caused the product defect to occur?
- How many unsafe products are there?
- Where are the unsafe products located?
- Did the product fail to comply with any safety regulations?
- Can we trace all units of the contaminant throughout from the manufacturing stage to the distribution stage?
If a recall is needed, there are quite a few responsibilities that will span across a range of positions. Having a team in place and specific people accountable for each responsibility will improve your recall efforts.
The recall team should be made up of different trained individuals from a variety of departments who can effectively execute each procedure of a product recall.
When a product is recalled, the team should evaluate the seriousness of the recall and determine what actions need to be made prior to notifying the FDA recall coordinator. This ensures that you are providing the appropriate and final details. Once the decision is finalized, the team should determine the direction of communication and who is responsible for managing the recalled products and who can coordinate other responsibilities.
When delegating recall responsibilities among individuals across the team, here are some things to think about.
- Accounting
- Management
- Operations
- Production
- Quality Assurance
- Consumer relations
- Customer service
- Legal counsel
- Marketing
- Sales
- Distribution and supply
Here is an example of a recall team contact worksheet.
After the team has been established and the person in charge of the recall is in place, guidelines should be set to help determine when to enact a recall. Issuing a recall will be different for every company, depending on its production.
Here are three different scenarios that may cause a food recall.
- A government agency requests that a product be recalled. The product can either be tested to confirm or deny the problem, or management can decide to perform a recall immediately.
- A company receives enough customer complaints to activate a recall. The product then could be tested, and management can make their decision.
- A recall can be determined if the company tests and monitors the product internally and determines that it’s been contaminated or defective. If the product has left the facility, management can decide and act accordingly.
When you think about how a product can be successfully recalled, it largely depends on how accurately the company’s records can identify specific products by criteria, like model numbers, batch numbers, and serial numbers.
It’s important that companies have a robust inventory management solution in place to increase traceability and keep records on file to help tracing all the raw ingredients included in the product and all the stages of manufacturing or production. A system that has efficient tracking capabilities and identification record systems in place will ensure the products that may need a recall are identified quickly. Detailed and accurate tracking capabilities enable companies to confidently and quickly make decisions about how to handle each recall step.
How companies maintain consumers’ trust during a recall is key. Companies can do this by maintaining transparency, responsiveness, and consistency.
Existing communications platforms can be used to publicly acknowledge the recall and reinforce their commitment to consumer safety and how they are handling the problem.
Companies in the food and beverage industry generally should prepare a press release that will communicate the proper message to the public, and partner with a good public relations team to craft the message and release it strategically.
How companies react, implement a recall plan, and engage with the public will go a long way. Some might say, it’s how they will be remembered and viewed moving forward. Preparing and developing a proper recall plan and executing it at the right time can make all the difference.