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How to build a comprehensive plan for food recalls and brand protection

May 20, 2020
CMX
by CMX
CMX
by CMX

How to build a comprehensive plan for food recalls and brand protection

 

Global food supply chains are more complex and interdependent than ever. As consumers, we all benefit from having more choices, lower prices, and year-round availability of many food items that were once only seasonal. Unfortunately, this added complexity also increases risk and is a catalyst for food safety failure. The more moving pieces you add to the puzzle, the more things can go wrong somewhere down the line. 

Grocery stores, restaurants, and food manufacturers that are unprepared for a food item withdrawal or recall notice jeopardize their reputation, facing significant economic and social consequences. But, knowing how to perform an effective food recall or product withdrawal—through quick action and effective communication—is the best way to limit your company’s exposure and mitigate the damage to your reputation and bottom line. 

 

Performing a mock recall-1

 

So, how do you set up a recall management plan and prepare your team to ensure that your food recall process is executed in a fast, effective, and accurate manner? These days, it comes down to having a product recall strategy and a powerful recall management system

But what does that look like? Let’s find out. 

 

Food recalls on the rise which impact consumer trust

In an age of 24-hour news and social media - quality, food safety, and trust is on the forefront of customers’ minds. These concerns have only been elevated further during the COVID-19 crisis. But even before the pandemic, food safety issues were on the rise and rapidly becoming a global problem—all impacting customer trust. As Food Logistics points out, “Over the past few years, recalls and restaurant closures have populated the news cycle, highlighting the harsh reality no establishment is immune to crippling foodborne illnesses lurking within its supply chain.”

Despite a food producer's best food safety control efforts, sometimes, unsafe products make it to market. These potentially harmful products could contain pathogens, have improper labeling, undeclared allergens, or fail to meet regulatory requirements. Regardless, if they pose a hazard to the general public, government agencies such as the Food and Drug Administration (FDA) and/or the U.S. Department of Agriculture (USDA) may issue a Class I, Class II, or Class III recall—with Class I being the most alarming and Class III being the least.

 

Some recent examples of recalled products include:

Put simply, this is a critical issue for every retail food brand and manufacturer, and it’s only growing larger. 

 

Taking proactive measures with a recall program

The Food Safety Modernization Act  (FSMA) marked a noticeable shift in how the FDA and CDC treated and monitored foodborne illnesses, transitioning from a passive approach to a proactive one. Instead of waiting and responding, they sought to create a system that was preventing costly and deadly foodborne diseases from spreading. 

Under 21 CFR 117.139, FSMA requires facilities to establish a written recall plan for food that requires a preventive control. While manufacturing facilities are specifically called out, it is prudent for retail organizations to establish and implement a written recall plan as well. A well designed recall  plan and a recall process will allow for the removal of products from the market as fast and efficiently as possible, which can protect you from liability, repetitional harm, and significant economic loss. 

What must you do to create a comprehensive recall program? 

 

Nominate a predetermined Recall Management Team

To start, it’s crucial that you identify a group of individuals with assigned roles and responsibilities as part of a recall management team.

This group will be headed by a Recall Coordinator who will oversee the team’s efforts to:

  • Communicate with internal stakeholders, supply chain partners, and “direct consignees” (retail locations and/or the public in some cases). Be sure to include legal, public relations, and marketing. 
  • Document processes and procedures
  • Decide how the decision to recall or withdrawal will be made
  • Document decisions and actions taken
  • Track the identification and removal of food product

The team should also be responsible for conducting mock recalls, ensuring the proper procedures are in order, and coordinating actual responses. To do this properly, with speed and accuracy, your hand-picked team requires a food recall management software system with comprehensive automated record keeping. During a recall, the system can act as the central information hub. With automated record keeping and reporting, it can be used for debriefs with C-Suites or FDA audit checks. 

 

What does a food recall process include? 

The goal of an effective recall plan is to quickly identify each impacted product, know where it is in the supply chain, and know who to contact so that they can remove it. To do this, there are several steps your team must take the moment a recall alert occurs. Generally speaking, they are:

1. Investigation – Identify and document the source or cause for the flawed food product or ingredient. It is also important to evaluate and document the potential/actual health hazards involved.

2. Initial Actions – Gather your recall team for additional analysis and decision on whether to take action. If recalling, consider the depth of the recall (how widespread, which channels) and which stakeholders, partners, customers, and regulatory agencies will need to be notified.

3. Identification – Determine all of the food products that are impacted and require recall. This should include product name(s), size(s), lot number(s), code(s), expiration dates, and labels and photos if possible.

4. Recall Action – Put a hold on impacted products that are within your control, and create a distribution list for potentially impacted parties.

5. Notification – Alert your distributors, locations, customers, and the press and public (when applicable) and inform them how to proceed. Notification may include letters, emails, or even text messages. These all have permanent records. The FDA recommends when communicating by telephone, that the recalling organization be sure to document phone communications “in an appropriate manner”.

6. Removal - Your team will need to determine what to do with the food products being recalled. In many cases, perishable food products will be destroyed. In other cases, products may need to be returned. When sending notifications, it is imperative that your instructions are clear on how to identify the products and what action they are to take, and how to communicate back with the recalling firm.

7. Root Cause Analysis (RCA) and Corrective Action – Despite best efforts for preventative measures, when issues arise, it is critical to address the issue which caused the recall. Performing a Root Cause Analysis (RCA) will allow your team to identify the what and how behind the issue appearing, and what corrective action is required to prevent its reoccurrence. 

Pharmacy Recall Management-1

The benefits of applying automation and software designed for managing food recalls

While many brands try to manage this process manually, there are a great number of benefits to applying technology specifically designed to automate these processes:

 

Automated processing and monitoring of product complaints 

Manually dealing with product complaints and monitoring trends is time consuming and puts you in a reactionary mode. Systems designed to manage and monitor complaints can act as an “early warning system” for impending issues. Leveraging technology to process complaints, monitor trends, and provide safety alerts for elevated trends, can prompt your team to take early investigative action and remove products before the risk becomes wider spread. 

 

Shorten the time it takes to create a distribution list and get the word out

If you have hazardous products in your supply chain, taking action as soon as possible is absolutely critical. Compiling a list of contacts can be one of the most time consuming tasks, when time is of the essence. Software designed for food recall management that also integrates with your supply chain data sources can make this job much easier. From there, your recall management system can automatically and instantly reach out via email, phone, and text - issue withdrawal or recall notices, and escalate to field management in order to guarantee a rapid response.  

 

Ensure action is being taken 

Once notifications have been sent out, it’s vital that you get responses from every party and know how much product has been recovered. Doing this with email and manually tallying up the results isn’t efficient. Software can track responses and provide reporting in real time in order to measure the completeness of your recall. This also creates more transparency and with actionable information to manage the recall process as it unfolds.   

 

Test your food recall readiness with mock recalls

Before a recall ever occurs, you and the key members of your supply chain should be familiar and practiced with recall procedures. So, when the alarms ring, they’re prepared to move swiftly and effectively. To ensure your preparedness, it’s critical that you perform regular mock recall tests in order to see what works and what doesn’t, and then make the necessary adjustments. Software designed for food recalls can provide much needed mock recall functionality to ensure your team and supply chain are ready for the real thing when needed.

 

Taking the Crisis Out of Crisis Management

Ensuring the quality, consistency and safety of food is no easy job. Products and supply chains are far more complex than ever. Risks are prevalent. When issues arise, taking decisive and swift action is critical to the safety of your customers and your brand’s reputation. In today’s age of digitalization, no food manufacturer or retail food service company should be without product recall strategy and a powerful recall management system. 

 

Other Resources

Looking to learn more about how to best manage food recalls, protect your customers, and protect your brand? Here's a an article we wrote that originally appeared in Food Logistic Magazine.

We've also created a handy guide on how to conduct Mock Recalls that might be useful.

 

Food Recall Software from CMX

CMX1's Recall Management system has all stages of a recall event covered, and all the features needed by your crisis management team to manage the recall process. Perform investigations, communicate with your supply chain and locations, and monitor food recalls in real-time. Everything you need in one place including automated record keeping.

Reach out to us today and one of our experts can show you how to get the ball rolling to make performing recalls much easier. 

 

Sources 

FDA. Recalls, Corrections and Removals (Devices). https://www.fda.gov/medical-devices/postmarket-requirements-devices/recalls-corrections-and-removals-devices

CNBC. Kraft Heinz recalling cheese dip on botulism risk. https://www.cnbc.com/2018/07/25/kraft-heinz-recalling-cheese-dip-on-botulism-risk.html

ABC. Tyson Foods recalls 39,000 pounds of frozen chicken patties possibly contaminated with 'foreign matter'. https://abcnews.go.com/US/tyson-foods-recalls-39000-pounds-frozen-chicken-patties/story?id=65019534

USA Today. Over 2 million pounds of P.F. Chang's frozen meals recalled for 'undeclared allergens'. https://www.usatoday.com/story/money/2019/05/06/p-f-changs-2-million-pounds-frozen-meals-recalled/1115948001/

FDA. Food Safety Modernization Act (FSMA). https://www.fda.gov/food/guidance-regulation-food-and-dietary-supplements/food-safety-modernization-act-fsma

Root Cause Analyses Are ‘Critical to Preventing Foodborne Illnesses’, A Q&A with Frank Yiannas, FDA deputy commissioner for food policy and response.https://www.pewtrusts.org/en/research-and-analysis/articles/2020/03/24/root-cause-analyses-are-critical-to-preventing-foodborne-illnesses

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