How to Manage a Recall Effectively

In the food and beverage industry, brand equity is imperative to an organization’s success. A recall is one of the most devastating things that can happen to any organization within this industry. Added to the cost to consumers and the U.S. Food and Drug Administration (FDA), there are regulatory issues and negative customer reactions to address, as well as the possible effect on market share to consider.

Recently, publicity has increased surrounding recalls of products like peanut butter, spinach, and pet food. Companies must establish measures to effectively mitigate recall risk, or, if a recall is necessary, to manage the process as quickly and efficiently as possible.

Fortunately, companies can employ several methods to lower their recall risk, including proactive measures such as implementing food safety initiatives to enhance quality and safety in the production process and adopting technology solutions such as a quality management system (QMS).

Proactively Mitigating Recall Risk

Clearly, preventing a recall is better than conducting one. Incorporating safety and quality into food manufacturing lowers the overall recall risk. Food safety processes such as hazard analysis and critical control points (HACCP) and initiatives such as Safe Quality Food (SQF), International Food Standard (IFS), and the British Retail Consortium (BRC) have been established to ensure that safety practices are followed and the safest possible food is produced.

In addition to the existing food safety measures, there are several proposed bills in Congress that would give the FDA even more power over the areas it oversees, enabling the agency to reduce the risk of defective food being released to the market and ultimately reducing the recall rate. These include:

• The Food Safety Enhancement Act: This act serves as a proactive measure for food safety by preventing food safety problems. It creates an up-to-date registry of all food facilities that serve consumers in the United States and requires all U.S. food manufacturers and food importers to register annually. It requires each food facility to conduct a hazard analysis and establish a food traceability system. The act ultimately enhances the FDA’s ability to block unsafe food from entering the food supply.1
• The Safe Food Enforcement, Assessment, Standards and Targeting Act of 2009: This act requires food companies to implement food safety plans and register with the Secretary of Health and Human Services annually. It allows the FDA to order recalls, detain unsafe food, and set traceability requirements.2
• The Food Safety Modernization Act of 2009: This initiative strengthens enforcement by granting the FDA capabilities that include ordering recalls, requiring that all products be traceable, detaining and destroying unsafe food, and applying civil fines to those organizations that break laws.3
• Food and Drug Administration Globalization Act of 2009: This act would enable the FDA to order recalls, require that all products be traceable through the use of electronic records, fine noncompliant organizations, and protect whistle-blowers from retaliation.4

While these initiatives are intended to incorporate safety into each step of the production process, it would be impossible to mitigate the need for a recall completely. Therefore, an organization must prepare for a recall event and must ensure that the recall process is as efficient and painless as possible.

Let’s review an ideal recall management scenario and describe how automated tools enhance the process.

Recall Information to the FDA

Once it is determined that a recall is necessary, the process must be put into action immediately. The FDA must receive all product-related information—the recalling manufacturer’s name and information, the reason for recall (including a detailed description of the defect), how this has affected the safety of the product, and the date the issue occurred.5 The company must also include the volume of food product that was produced. Additional information that must be submitted includes the quantity and distribution dates and the amount of product that is on hold due to the recall, along with the distribution pattern. The company must inform the FDA of the number of direct accounts in order to retrieve all products from facilities and consumers.