The DNA of Recall Crisis Management

There are some important questions to ponder: How do you currently perform your root cause analysis? Do you rely only on internal data such as the production schedules and plant line reports (e.g. to confirm there wasn’t a glass breakage event when handling a glass foreign object complaint?) and arrive at your best approximation of the cause? Do you sometimes feel like that determination is based more on an educated hunch than scientific evidence? Would you prefer to have more concrete information that better substantiates the merits of an alleged consumer complaint?

If you answered “yes” to any of these questions, your company may benefit from familiarizing itself with and utilizing the most recent, innovative forensic resources to support its investigation and resolution of alleged contamination claims.

For those in the food industry, determining the merits of an alleged claim is oftentimes more of an art than a science. But engaging the skills of a credible laboratory that performs myriad forensic analyses may significantly improve your ability to determine the identity and source of the contamination, how it entered the product, at what point in the distribution cycle and, possibly most importantly, by whom.

If your company faces the potential of a major recall, your goal is to leave no stoned unturned in determining the root cause of the alleged issue. If you are facing a foreign object claim, for example, your mission is to determine how it could have entered the product. Testing and analysis performed by an independent national laboratory brings legitimacy to your investigative findings. By using certain innovative forensic testing technologies employed by many laboratories, you may be able to confirm through credible, industry accepted testing methodology that the foreign object was introduced by the consumer complainant, not your company. These results serve as primary evidence in your defense to the claim, thereby potentially shielding your company from liability and protecting your brand and company’s valuable reputation.

So, what’s the takeaway? In addition to having a well-written recall plan with clearly defined roles and responsibilities and standard operating procedures to follow in the event of a recall, use of forensic testing may be one of your best crisis management tactics and most conclusive defenses against product contamination claims. But a word of caution: the converse may also hold true—forensic testing may produce results unfavorable to your position in confirming that the contaminant was indeed introduced under your watch. Therefore, you need to be prepared to handle this possibility from a communication and brand protection crisis management perspective. Your cross-functional recall decision team should include a representative from media relations and the affected brand in order to be properly prepared to address the potential ramifications of a product recall.

Laboratories Offering Forensic Testing

Many laboratories offer clients a variety of forensic food testing methods. However, in order to differentiate between the numerous offerings of testing labs and select one that aligns with your high quality standards and meets your particular testing needs, careful due diligence is necessary. Of primary importance is determining whether the laboratory is ISO 17025 accredited. The April/May edition of Food Quality contains an excellent checklist, which expounds upon the ISO 17025 accreditation standards and provides additional helpful tips to consider when making your selection.

As for resources and laboratories who may offer the forensic testing services you are seeking, the following list provides a few of several that offer such services:

1. FDA Forensic Center, established in 1989, the center provides a team of forensic scientists who can provide forensic testing services and advice to FDA officials. Although this agency does not do contract work for individual companies, you should be aware that FDA possesses and utilizes such expertise (www.fda.gov).
2. Food Processors Association’s (FPA) Center for Technical and Laboratory Services (CTLS) offers forensics services to its membership (www.fpa-food.org).
3. The Institute for Environmental Health, Inc. (IEH) offers a variety of forensic investigation tools such as DNA-based methods to detect sources of contamination. For example, IEH is developing an expertise in genotyping E. coli in order to identify and track it through the supply chain system.2 www.ieh.com
4. The McCrone Research Institute utilizes state-of-the-art forensic microscopy testing (www.mcri.org).

Conclusion

If you are faced with a product recall, and determining your root cause of the contamination presents itself as the potential key in solving your mystery, consider utilizing forensic testing as a resource in your investigation.

References:

1. www.fda.gov. FDA Forensic Center
2. www. Iehinc.com ‘Genetic Fingerprinting and Forensic Investigation

Melanie Gilbert is RQA, Inc.’s vice president of crisis management and general counsel. She can be reached at 630-512-0011 or [email protected].