Fonterra and the C. Botulinum Scare

3. Incorporate food safety expectations in all new employment agreements.

4. Improve the management of customer complaints and export non-conformances with respect to escalation, root cause analysis, response, and continuous improvement opportunities.

5. Amend people’s performance objectives across the organization to reinforce the emphasis on food quality and safety as a mandatory objective.

6. Develop a comprehensive suite of people initiatives to lift the focus on food safety and quality.

Products – Quality Control and Testing Regimes During Manufacturing

7. Reset of Hautapu site. (“This encompassed further checking and servicing of all equipment and processes to ensure it continues to meet the highest possible international standards,” Maury Leyland explains.)

8. Establish interim Sulphite Reducing Clostridia testing program.

9. Conduct a specialized audit of Fonterra’s most sensitive plants that make ingredients or products consumed by infants and very young children.

10. Identify and audit any nonstandard or temporary manufacturing setups in Fonterra’s New Zealand plants.

11. Introduce more robust systems to authorize and ensure compliance of any nonstandard processing (including rework) and testing.

12. Conduct specialized quality audits for all Fonterra sites, including offshore businesses, third-party manufacturing, and joint ventures.

13. Conduct a full review of product standards with clear focus on when product is placed on hold and authorizations around release.

14. Explore options to more proactively align with customers and regulators on standards.

Systems – Traceability

15. Define, document, and communicate traceability protocols for all areas of the business.

16. Conduct an immediate review of significant system changes planned for product traceability and customer complaint management to ensure adequate change and risk management.

17. Conduct a wider review and overhaul of Fonterra-wide product traceability capability, including product outside of Fonterra’s control.

18. Institute a quality hotline for Fonterra staff and contractors to encourage early escalation.

Response – Transparency

19. Ensure Fonterra has a well-rehearsed crisis management capability.

20. Review and clarify communication protocols with respect to third parties (including customers, industry bodies, and government) in a crisis.

—L.L.L.