Recall! This is a word that can bring significant fear and concern for any food business. In particular, small companies who may not have the experience or systems to deal with recalls may find themselves in difficult circumstances in the event of a food safety issue and associated recall. Fortunately, significant food safety recalls are relatively rare. However, it is important for all food companies to devote the time and resources needed to ensure that their products are safe, properly labeled, traceable, and retrievable. The purpose of this article is to outline areas to focus on to be ready for a recall and to provide some information on what to expect in a recall scenario.
Have a strong food safety program
Obviously, the best way to manage recalls is to never have one! Unfortunately, there is no such thing as a perfect food safety system. The best strategy is to have rigorous food safety programs in place including Good Manufacturing Practices and Hazard Analysis Critical Control Point (HACCP) based systems. Small companies may not have the capacity to achieve certification under one of the Global Food Safety Initiative (GFSI) programs. Fortunately, these programs are increasingly adapting to the needs of smaller businesses. Still, certification under a GFSI-based scheme is often not practical for smaller enterprises.
There are many options for more streamlined programs that are available to meet the food safety requirements of a small business. At a minimum, some staff should have current food safety and HACCP training, and a documented HACCP program should be in place. It is recommended that the food safety program be audited by an external expert or organization at least once a year. In some cases, regulatory inspections will serve this purpose but only if they are focused on a comprehensive HACCP-based system approach.
Focus on areas of food safety programs that will help in a recall
Although the totality of a food safety system will be the foundation for preparedness and management of a recall, there are three areas of every system that are particularly important to focus on from a recall point of view. They are: Traceabilty, Supplier Assurance, and Mock Recalls.
Most food companies recognize not only the practical necessity of a product coding and tracking system, but also the regulatory obligations that are now in place and will likely be made more rigorous with the implementation of the Safe Foods for Canadians Act and Regulations. Production coding to the narrowest window of time that is practical, is the best approach. Often companies use production codes that cover an entire day’s production. While this may be a simple and practical in most situations, it can lead to withdrawal of much more product than may be necessary if a recall were to occur.
It is also extremely important for companies to be able to trace back to the origins of all ingredients, packaging and labeling. Very often the cause of a recall is linked to problems with these inputs and not the company’s production, storage or shipping processes. Having records of all ingredients, packaging and labeling and their use in production is essential to being able to establish a product withdrawal program during a recall.
Detailed distribution records are also critical. Normally this is not a problem area, but there are some sectors where deliveries are made on a just-in-time basis and orders are last minute, and hastily prepared. A company must know to 100% accuracy where products have been distributed to the first level beyond the plant or warehouse. Any amount of product that is unaccounted for, or even minimal errors in distribution records, can lead to all kinds of unforeseen problems during the intensity and pressure of a real-life recall situation.
Information systems for traceability have to be fast and reliable! The effective management of a recall hinges on being able to get correct information out to customers, consumers, and regulatory officials as quickly as possible. Delays bring questions and doubt. Incorrect information can lead to additional recalls for the same or similar products which can damage credibility and lengthen the time required to manage a recall. Getting it done fast and right the first time is the key to success. Whether it is an inventory software program, or in-house spreadsheets, or even paper-based records in small companies; these systems must be maintained and always functional and accessible, even when key company personnel are not available.
Testing the traceability system on a regular basis is required by all HACCP and food safety systems. There is often confusion between traceability exercises and mock recalls. The two are linked but a trace exercise is focused on accounting for all inputs, production, storage and distribution. It is primarily a product counting and verification process. Companies should test themselves on traceabilty – inventory, input use, and distribution, several times a year. Experience has shown that errors are often uncovered and systems become much better on each testing.
Mock recalls are a great tool to help prepare for the real thing. Unfortunately, these exercises are either overlooked or undervalued by many companies. Unlike traceability exercises, the goal of a mock recall is to test everything in the company’s system including such things as communications strategies for the media and consumers, product withdrawal procedures, verification of withdrawal from the marketplace, alternative sourcing of products, notifying and managing customers affected, and working with regulators who will be demanding information and directly involved. The mock recall is an opportunity to develop scenarios that truly test the whole system. It is best to keep in mind that recalls always seem to happen at the worst times. Conducting some mock recalls outside of regular work areas is a good idea.
One of the most frustrating and difficult scenarios for recall happens when the cause of the recall is an ingredient or packaging. These inputs are purchased with the expectation that they are safe and of good quality, but mistakes happen and these can have major implications for companies using these unsafe or defective input materials. It is worth spending the extra time and diligence to ensure that everything received and used in a food product comes from a reliable supplier. Wherever possible, letters of guarantee, certificates of analysis, or evidence of the integrity and status of the supplier’s food safety systems should be sought, reviewed, and kept on file. Establishing and abiding by an approved supplier list is often an easy thing to do for a small business and can greatly reduce the likelihood of food safety issues leading to a recall.
What to expect when you have a recall
Getting the news that there is a problem with a product and finding out it has already been distributed to the retail/consumer level can create chaos if a company is not well prepared. Having an established plan and trained people in place will go a long way to ensuring that good decisions are made, and actions taken that make the process as orderly and effective as possible. After assembling the Recall Team, the first step in a recall response is to contact CFIA, and key customers who may have the implicated product. The team should also begin immediate work to define the identity and locations of products and develop the detailed logistics of product retrieval or disposition.
Regulatory Aspects of Food Recall
Under existing federal regulations, companies must report food safety incidents and make records available to government inspectors. There are time limits for providing information and quality standards for these records. They must be well organized, complete, and if electronic, in a readily accessible format. Under the new regulations that will be proposed under the Safe Food for Canadians Act, it can be expected that standards for records and their availability will be made more rigorous. It is important to recognize that recalls in Canada are almost always done voluntarily by the affected company. There is a provision in federal legislation that allows for the Minister responsible for the Canadian Food Inspection Agency to order a mandatory recall, but this is seldom done because companies normally take responsibility and execute measures necessary to withdraw product from the market place.
What will CFIA do in a recall?
CFIA has a network of recall specialists across Canada with a centralized Office of Food Safety and Recall in Ottawa (OFSR). The first contact for most companies will be to a CFIA Area Food Recall Coordinator. Basic information will be collected initially and the file will be reported to OFSR. An investigation will be initiated to get enough information for a decision on a recall. Companies can expect to be asked for many types of information i.e. production and distribution records, product sampling and analysis, CCP monitoring, internal inspections, supplier records etc. Company owners or employees working with CFIA need to be as open, responsive, and co-operative as possible. The food safety investigators’ focus will be strictly on food safety and limiting risk to consumers and they will require complete information as quickly as possible.
After the required information has been gathered, the OFSR will contact Health Canada who will make a final decision (Health Risk Assessment) on whether a recall is needed; and also the scope and category of the recall (Note: CFIA’s website provides details on recall categories: inspection.gc.ca – go to Recall Plans Manufacturers Guide). CFIA is the operational organization responsible for ensuring that the recall is conducted by the affected company. Note: In cases where product has been distributed to the U.S. or other countries, companies need to contact appropriate regulatory agencies in these jurisdictions. CFIA will work closely with U.S. or other country authorities to share information and coordinate recalls.
In cases where a food borne illness outbreak occurs, public health officials will lead the investigation and management of human health issues. The Public Health Agency of Canada leads where illnesses have occurred in more than one province. A localized food- borne outbreak is investigated by provincial or municipal public health officials. Although public health inspectors are not normally directly involved in the recall process itself, their investigations provide key information to the CFIA recall process.
There are three categories of recalls based on level of risk to human health. These categories determine key actions required, including whether or not there is a need for the recall to be announced publicly. In addition to company-initiated public notices or recalls, most recalls are posted on CFIA’s website, www.inspection.gc.ca. Once a company has made every effort to retrieve control of as much of the affected product as possible, CFIA will conduct recall effectiveness checks at retailers to provide reasonable assurance that the company has withdrawn all products from the market. Likewise, companies should be checking the marketplace for recalled products. As quickly as possible, during or immediately after a recall, a root cause analysis must be conducted and corrective actions implemented and verified.
While it is not the intent of this article to delve into the world of risk communications, there are some basic things that are essential for companies to consider when faced with a recall attracting media and public attention. It is essential to have a well prepared and credible spokesperson ready for the media to talk to. Speaking points should be developed and the spokesperson should stick to these points. The message is always – Food Safety comes first, and the company is doing everything possible to protect consumers. If a recall is associated with illnesses, the media and public attention will be heightened and it is prudent to have both legal and communications experts provide advice in these situations.
A) Help during a recall
When a recall happens, companies can quickly become overwhelmed by the demands for information, decisions, and actions. Many companies recognize this challenge and incorporate external help as part of their recall planning. Some firms have pre-determined specialists or consultants they can call on to help with advice, technical communications, or even direct management of the recall. This approach can be of particular help to small or medium-sized companies who do not have in-house expertise in this area.
Some insurance companies who specialize in the food processing area provide incentives for policy holders who are willing to implement enhanced emergency and recall management preparedness measures. This could be a good way to reduce both risk and costs at the same time.
The motto “be prepared” is the overriding theme when it comes to food safety issues and food recalls. While it is always the fervent hope that a company will never have to deal with a food recall, even the best-run firms may face an issue at some point. Better awareness and basic planning can put any company in a good position to manage a recall effectively and continue to thrive as a business.
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