Product Recalls:
Readiness is Key

Staff Report

Nobody wants to think about a product recall but nobody should put themselves in the position of having the first time serious thought is given to a product recall coincide with a recall of his/her product. Recalls have a considerable impact on a company’s business and when involving an ingredient, can impact a number of other businesses as well.

No matter what the cause, the impact of a recall can be reduced when a company is prepared for the possibility via a plan/program. Navigating through a recall requires planning, knowledge and practice. Recalls are often complex; failure to have a plan in place and to have performed a mock recall can make things more complex and increase the scope of the needed recall. Having a robust and tested recall plan can be the difference between a company closing its doors or surviving. Recall plans are also required by the Food Safety Modernization Act – both for (U.S. and foreign) suppliers and U.S. importers.

The recall plan must be written. It describes steps to take and assigns responsibility to do the following:

  • Notify direct customers and consignees, tell them what food is being recalled, and inform them how to return or dispose of the food.
  • Notify the public, when appropriate, about any hazard in the food, particularly in Class 1 and sometimes in Class 2 recalls.
  • Conduct effectiveness steps to make sure the recall was carried out.
  • Execute disposition of the food through reprocessing, reworking, diverting to a use that is not unsafe or destroying it.

One of the most-common recommendations regarding recalls is that companies should create a recall committee. One of that committee’s first task should be the creation of a recall checklist. A cross-functional team also will be needed to carry out tasks related to recalls. For example, the quality assurance department will need to assess the problem and take steps to ensure it’s not continuing; legal departments will need to address legal issues; communications departments will need to produce the messages shared with clients and/or consumers; and finance departments will have to manage credits, expenses, etc. Procurement (to get replacement product), warehousing, etc. might also need to be involved.

The committee should be led by a recall coordinator. That person should document all actions, coordinate and manage the company’s recall and have the power to make recall decisions on behalf of the company.

Many of the people reading this publication own or work at smaller companies that don’t have some or all of the departments mentioned above. They’ll either need people to undertake several roles in this process and/or get assistance from third parties. Again, the time to vet those third parties is before they’re actually needed.

Practicing a company’s recall plan is the only way to ensure the team is prepared to efficiently handle a product recall. The checklist below, produced by Recall InfoLink, provides a framework for practicing a recall.

  • Create a recall committee with a point person and designated responsibilities.
  • Develop a scenario that could cause a recall or product withdrawal to occur.
  • Gather the relevant information about the possible product problem.
  • Use the facts to decide whether to recall and determine the recall scope.
  • Determine any regulatory compliance issues that must be addressed.
  • Collect all relevant item information for each item in the recall.
  • Determine which of your customers are affected by this recall and build a file.
  • Determine the quantity of items shipped to fill purchase orders to each affected customer.
  • Prepare communications pieces for each audience to be notified (customers, regulators, consumers).
  • Reconvene the recall committee for review and approval of prepared actions.
  • Communicate with all customers.
  • Manage customer responses, product returns and resupply needs.
  • Prepare and implement corrective actions.
  • Reconvene the recall committee as required to monitor progress and respond to any new developments.

Some smaller producers and U.S. importer/distributors don’t have lot coding for their product – a big mistake. Careful tracking of your products and identification of the sources of your ingredients will determine the effectiveness of a recall and will impact on how much product you will need to take off the market. Unidentified or badly identified lots hinder the recall and can lead to either more of the unsafe product getting onto the market or more product being recalled than is necessary, both bad for business.

Association of Food Industries: Serving the U.S. Food Import Trade Since 1906
3301 Route 66, Ste. 205, Bldg. C • Neptune, NJ 07753
(732) 922-3008 • Fax: (732) 922-3590 • afius.org • info@afius.org