In recent years, the numbers of recalls being announced by the food industry have been increasing substantially. Much of the increase is driven by additional regulatory initiatives, which continue to intensify and expand. Thus, if you remain hopeful that you’re company will never be involved in a food product recall, think again.
When that day eventually comes, and it will, it will be critical that you are prepared. Indeed, as with most everything in life, there are a few “rules of thumb” that you can follow.
I call these the “four C’s of recall management:”
- Compliance; and
Containment: The first and primary goal in any recall is always containment. When the phone rings, and FDA or USDA informs you that there may be a problem with your product, it is absolutely critical that you quickly identify the underlying problem and contain the issue. For this reason, it is essential to have a system in place which will enable you to immediately identify which batch, and which finished products, might be implicated. While many companies give themselves 24 hours to accomplish this task, you should work toward the goal of accomplishing this in 30 minutes or less. The sooner the problem is contained, the sooner you will be able to limit your regulatory and liability exposure by preventing further distribution or additional consumers from being exposed.
Communication: Once the underlying issue has been identified and contained, you can begin communicating with your customers, the public and (if necessary) the media. When communicating directly with your customer and the public (often in the form of a recall release), you should detail the reason for the recall, identify with precision the specific products which are affected, identify which products are not, and explain what your customers (and, by extension, consumers) should do with the affected product. In the event the media calls, tell them you are happy to discuss the issue, but have them email their questions – so that you have ample time to review and think about the most appropriate response.
Compliance: After a recall is announced, FDA or USDA will likely conduct a compliance visit to ensure that all affected product was contained and the recall was properly communicated to your customers. These agencies will also likely spend a few days (or a few weeks) in your facility, conducting a comprehensive inspection or food safety assessment.
Thus, the moment you begin executing your recall plan, begin preparing for the inevitable visit from the relevant government agencies. Make sure that all of your efforts are appropriately justified and documented, so that you can quickly and clearly convince the compliance officers that the scope and execution of the recall was appropriate and effective.
Closure: By following these three simple rules, you can effectively navigate the basic elements of any food product recall, and have confidence knowing that you can bring your recall to the last, and most important, “C” … which is closure.