We are presently assisting clients with either an active recall or with creating a recall procedure that is acceptable to both the USDA and the FDA. Whether it is pet food or airbags, recalls have become a part of our daily life.
As a food manufacturer this is one of your nightmares, especially since a recalled ingredient can force you to recall your product and permanently affect your brand. Below is an article we published on Catalant a few years ago, but it is still appropriate for today.
3 Things to Have in Place Before You Face a Recall
According to a 2011 survey by the Grocery Manufacturers Association 58% of their members had faced a product recall during the preceding 5 years.The FDA (Food and Drug Administration) Safety Recall archive for 2014 lists 396 individual actions.Given these statistics, if your company is not prepared to conduct a recall, you are gambling and the odds are not in your favor.The problem with small manufacturers is that their limited human and financial resources make recall preparedness an often-ignored task. The fact is that you not only have to worry about your own operation but also about the operations of your suppliers.The following 3 suggestions can save money, headaches and possibly your company if you ever have to do a recall.
1. Prepare a Crisis Plan and Rehearse it
A crisis plan needs to be simple and easily executed. As a small business, this plan starts with you – the owner or CEO. If you review potential crises that can happen to your business, you will find that they all have one thing in common: Attention from the Public, the Press and/or Regulatory Agencies.The most important element of your plan should be that there is one contact person for the outside attention and that person needs to be you. The second element is that you will be the face of your company. Thirdly, you will have to be transparent about what you are doing and why. It is always better to say, “I do not know” instead of “no comment”. Under no circumstances should you lie or cover-up.There are many public resources that will give you a road map to prepare your plan (an example for food processors)
2. Make Your Product Traceable
Whether you distribute or manufacture, trace-ability of your product will be the key in any Recall. It is also a great resource for your marketing and sales efforts.The simplest way to make your product traceable is having a unique ID number for it. If that is not possible, you will have to trace by other means, such as lot numbers. If you are working with lot numbers, make each lot as short as economically possible. This assures that tracing, recalling affects only that small amount, and it speeds up customer notification and damage control if the recalled product has entered commerce.Our manufacturing firm had set a goal of being able to trace 100% of a lot and notify the customer within 4 hours. When we were informed that one of our ingredients (pre-packaged diced onions) was being recalled, we were able to identify production lots at risk within that time.
3. Keep Consistent and Verifiable Records on Each Product Run or Item Sold
The corner stone of your quality control starts with the accuracy of the records on your receiving dock. Whether or not you are automated and scan in-coming raw material or if you manually log on paper records, this is where your tracking processes begin.You also should have a production flow plan with Critical Control Points built into your manufacturing to measure and record results.As owner or CEO, you need to walk your plant, and you need to spot check your records. If you find flaws, address them immediately and verify corrections.When something happens, these records will allow you to specify the limits for a recall. If nothing happens, these records will allow you to continuously improve quality and increase profitability.The Dollar cost of doing this is small and the benefits are huge. However, consistency and accuracy are a must.
By definition, a crisis will be unexpected. How you handle it, depends on how well you are prepared. Keep in mind that “The Buck Stops with You!”Be transparent and rely on the information under your control. Do not let your customers get the information from the media or through gossip. Be pro-active and stay ahead of the curve. Stay calm and be honest.