Regardless of how a recall may be triggered, the time to figure how to respond is not when a regulator from FDA or USDA’s Food Safety and Inspection Service shows up at the door. Food companies must first have access to a network of knowledgeable people and be able to contact them quickly, Dr. Acheson says.
While very large companies typically have this expertise in-house or readily available, most small- to mid-size companies have not previously faced a food safety issue and are usually unprepared to deal with it. “Determining the scope of the problem is important,” Dr. Acheson tells Food Quality & Safety magazine. “Doing or saying something that gets you on the wrong side of the FDA or USDA is not a good place to be because you will find yourself digging out of a hole.”
After contacting the appropriate people in your organization or through a network provided by a consultancy or lawfirm, the next step is to assemble and review your records, including where the ingredients came from, where they were stored, when they were used and in what lots, and when and to whom they were shipped. A final step involves communication, both internally to your employees and stakeholders and externally to the public, including the media, when appropriate.
“A recall is not a simple matter,” Dr. Acheson says. “It’s not just pulling back a product. There are many moving parts and many things can get screwed up. It’s also an incredibly stressful time. For many companies, it’s the first time such a thing has happened.”
Dr. Acheson also suggests a company should conduct a mock recall exercise that spans its production chain from supplier traceability to shipment. “That’s a way to diminish stress and will help you come out in good shape,” Dr. Acheson says. “Of course, you can do it without experience and get all stressed out and do things that end up diminishing your brand.”
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