Recall Management Driven by Risks and Regulations

Do not be afraid to challenge your traceability capabilities by selecting an ingredient that is used in several different finished products you produce to get a realistic assessment of your track and trace strengths and weaknesses. Don’t stop at the trace. Continue your simulation through to its natural conclusion which is the need to prepare an effective and appropriate communication plan for each audience impacted by the recall (e.g. actually draft a consumer level press release and/or a customer recall notification letter). We have seen many recalls remain in the media spotlight due to ineffective PR and communications strategies. Avoid the unwanted spotlight, and test in advance. This is not the time to take risks.

Call in the Pros

One of the best things you can do is “know what you don’t know” then call in the professionals. Use experts in areas where your organization may not have the bench strength needed in a particular food safety or recall incident. It’s important to recognize that experts are not only people with specific knowledge in a certain area, but also technology solutions providers and testing and equipment manufacturers.

Identify experts, call centers (for surges in call volume), and laboratories in advance. Take the time to educate these service providers on your business, products, and risk tolerance before an actual crisis instead of during one when every minute becomes a precious commodity you cannot afford to waste. Conduct all necessary vendor approval steps and establish these resources as fully vetted suppliers/vendors before you need to “turn on the light switch” and call them into action in an actual or threatened crisis situation.

It is best practice to have the following resources established and in your network of vendor partners ready, willing, and able to assist if you need them:

• Microbiologists,
• Medical experts,
• Toxicologists,
• Epidemiologists,
• Public Relations Firms,
• Attorneys,
• Laboratories,
• Call Centers, and
• Product Retrieval Firms.

Leverage Technology

In this era of heighted consumer awareness and sensitivities to allergens and country of origin information, as well as a global supply chain, sourcing from so many different suppliers from all over the globe delivers an ever-increasing amount of risk. This fact is difficult to ignore as we have seen many recent recalls caused by suppliers sending adulterated ingredients to a finished product manufacturer. Using technology to help manage this risk is a good decision to not only ensure compliance with regulations, but more importantly to ensure brand protection.

Some areas where food companies have best leveraged technology to mitigate the risk of a recall are as follows.

Inventory/Production Systems. Being able to quickly identify affected products subject to a recall is imperative. To facilitate this, it is of vital importance to document and retain relevant production information including date of receipt of ingredients and utilization in finished product(s) lot and/or batch codes, and distribution records. The use of electronic systems rather than manual records helps ensure this information is quickly accessible and accurately identifies the affected scope of the products to be recalled.

Supplier Compliance Systems. If companies are assessing and monitoring their supplier risk appropriately, they are asking suppliers to provide a lot of information—from food safety plans and allergen control programs to certificates of insurance and indemnification agreements. The days are numbered where industry can continue managing records manually. The more companies can leverage technology to manage its risk the better protected a company will be. Technology decreases the risk for human error and manages a plethora of critical data elements electronically to confirm suppliers are complying with expectations and risks are controlled, eliminating manually-kept processes.