Draft a detailed action plan. A good plan will make a recall smoother and faster. The plan should exceed the very basic FDA requirements to assign responsibilities—it should match product ingredients and their sources with bills of lading. If product recipients can’t be determined, the recall will grow exponentially larger, more expensive, and harder to manage.
Establish recall limits. Knowing when a problem started and when the cause was corrected will tell you what must be recalled. Belief is not enough; certainty is key. Establish the last documented evidence before the problem arose, the time the problem became known, and documentation that it was controlled.
If the product presents a microbiological hazard, it’s helpful to determine whether and when there was a resident or transient population of a pathogen in the facility. That knowledge will help determine how far back to extend the recall, and when to determine the product safety as well.
Prevention Tips
Now that the worst is behind you, what measures will you take to avoid a reoccurrence—and repair the company’s reputation? Here are some suggestions.
Perform a root cause analysis. A root cause analysis must be performed to determine why the problem occurred. Avoid the temptation to accept the most apparent cause. The FDA expects a thorough analysis that not only pinpoints the failure or failures that led to the problem, but also rules out other possible causes.
Root cause analyses can be painful. If the immediate cause is a worker who made an error, then worker training may appear to have been at fault. But that’s not really the root cause because management is responsible for assuring that worker training is robust enough to prevent problems. If you tell the FDA it was the fault of an employee, they may hear that management failed to assure proper training.
Once the root cause is identified, decide what will be done to prevent it from happening again. Superficial step-changes or quick fixes won’t prevent a repeated failure and they won’t protect the company’s reputation. Prevention means addressing the root causes from a system perspective, and that might mean re-examining quality control, safety, and reporting processes.
Instill a culture of food safety. Food safety training cannot be a one-time event. Use modern communication tools like an employee engagement smartphone app to keep food safety news top-of-mind and cultivate a sense of pride in a job well done.
Be a good corporate citizen. A well-received public response—and the return of the company’s reputation—depends on how well your audiences know and trust you and how willing they are to give you the benefit of the doubt.
Revive the company’s reputation and regain trust more quickly by visibly engaging in corporate good works, demonstrating commitment to social responsibility, responsible sourcing, nutrition, health and wellness, and sustainability. Express meaningful commitments publicly—online and offline—and share positive actions in a caring and credible way.
Plan for the worst. Ask yourself: What could go wrong? Develop thoughtful plans for the top three scenarios. Be sure to socialize the plan by conducting practice exercises and drills with both company leadership and frontline employees. And don’t forget to conduct on-camera media training with the official company spokespeople.
Develop relationships with outside experts. Invite scientific and academic experts to tour your facilities. Make an effort to visit their institutions and update them regularly on company events and milestones. This will provide allies who are prepared to vouch for your safety efforts in the future.
No food business is immune from risk. But by investing in your facility’s operations and in communications planning, you’ll rebound more quickly after an incident and regain your rightful place in the market—with the respect of your friends, followers, and customers intact.
ACCESS THE FULL VERSION OF THIS ARTICLE
To view this article and gain unlimited access to premium content on the FQ&S website, register for your FREE account. Build your profile and create a personalized experience today! Sign up is easy!
GET STARTED
Already have an account? LOGIN