Recall Planning Is Key for the Food Industry

In late 2002, the food industry again experienced a record-setting recall involving approximately 28 million lb of poultry products. While preparing to write this article, I thought of my own recent holiday experience with a familiar brand of turkey, and my astonishment at the company’s treatment of my complaint.

Bottom line, my turkey was bad—bitter tasting with discolored flesh, all undiscovered until the moment this 22-lb wonder was carved in front of my dinner guests. Perhaps I am a slightly more food safety–conscious consumer, but imagine my surprise when after two days of trying to get through on the company’s toll-free number, the call center representative had no interest in getting the product back for the company to assess.

I even prompted, “Don’t you want to test this and see what the problem is? What if there is a problem here that might cause you to consider a recall?” The representative politely informed me that there were no recalls on her list and I could just dispose of the product. Naturally, this reinforced for me one of the fundamentals in recall planning and readiness: how do companies ensure that consumer feedback is captured and reviewed with the appropriate level of knowledge and urgency so as to ensure that critical information is communicated to the recall coordinator or recall team?

Consideration needs to be given to the many channels through which information may be received by food manufacturers that may lead them to consider a recall. Suppliers may notify customers of an issue with their raw material. An internal discovery of a manufacturing failure may occur, or routine monitoring may surface an issue with product shelf life that was not discovered in the development process. Regulatory authorities may notify the company of testing results revealing the presence of pathogens. Consumers complain.

A company’s recall plan should consider how each of these situations should be treated, with time frames and responsible decision makers identified. It is essential that companies demonstrate due diligence in understanding the risks that may be associated with their product line, how to minimize or eliminate them in their processing, and what to do to determine if and when a product recall may be required.

The recall policy or plan should be in place well before it is needed and should define both the procedures and resources required to execute a successful recall. It should be tailored to the company’s operations and should anticipate the scope of possible product recalls based on product types, categories of distribution, and classes of trade, i.e., through direct store delivery, brokers or distributors, to supermarkets, foodservice, or vending. The plan should identify Recall Team members, alternates, and contact information. External resources such as medical professionals who may assist with health hazard evaluation, media, regulatory, law enforcement, and retrieval services should be included. Roles and responsibilities should be clearly defined, typically along functional lines, and a recall process flow chart or checklist should be outlined. During the recall, this allows a record of decisions and action items, persons responsible, and completion dates. Model communications to customers and the public should be prepared.

A recall plan should define the company’s lot trace capabilities, information systems contacts and procedures, and any training that may be required. Recall Team members should be trained in the recall process, crisis management, and even media relations. The company’s readiness should be assessed via mock product recalls, simulating a crisis and proceeding according to the established procedures. Once the recall policy or plan is in place, every employee needs to know whom to contact in the event of a recall.

Food scientists play a key role in both the planning and execution of a recall. Food safety and quality risks are considered in the product development and launch process. Ongoing support is provided to manufacturing and quality assurance to reduce cost or improve quality. Input should be provided to the consumer affairs organization on the types of complaints that could be received and the appropriate response, including complaints that should be returned for evaluation. And finally, food scientists may participate in the investigation and development of corrective and preventive actions in the event of a recall caused by an internal failure.

Food manufacturers understand that it is in their best interest to remove substandard product quickly to protect both consumers and their business. Responsiveness is a must, and swift action must be accompanied by accurate communication. Planning and readiness are the key to a successful recall.

by Mary Ann Platt is Executive Vice President of RQA, Inc., 7900 S. Cass Ave., Darien, IL 60561.