Since the Food Safety Modernization Act passed in 2011, Food and Beverage companies have been legally responsible for maintaining a traceability and recall program. This is to ensure that in an unfortunate event such as foodborne illness, contamination, foreign body, infection, allergic reaction, etc is detected downstream that a plan exists to identify the source of the problem, the scope of the problem, and to inform appropriate regulatory agencies. Having such a plan is vital to ensure public safety and to limit company liability. Adroit’s Food Quality, Safety, and Regulatory team can help you to formulate, review, or manage a recall plan. If you have a problem we can work with you to more effectively execute the recall.
To establish a recall plan form a cross functional team with authority to act. Consider who should represent Quality, Customer Relationships, Production, Shipping/Logistics, Regulatory Communication, Press Communication, Employee Communication, Legal, and Insurance.
A complaint process should be in place. Robust ERP systems like Ramco Food and Beverage ERP include the capability to record a Customer Case within the Customer Relationship Management (CRM) module. The complaint record should include specifics about the individual reporting the complaint, a full description of the problem, product information such as item code, lot #, production and expiration dates, history of product handling and consumption, and which if any regulatory agencies have been notified. Going forward, all decisions, communications, and actions should be captured against this complaint record via the Customer Relationship Management system.
The complaint should be reviewed by the Recall team. The individual responsible for customer relationships should reach out, supported by quality, and gather as much additional information as possible. Depending upon the severity and nature it may make sense to obtain the contaminated product for analysis. Contact the retail location that provided the product and again determines as much information as possible about the handling history, temperature records, etc. As quickly as possible develop a joint response with the individual retail location. If you are a distributor or wholesaler that provided the product determine via traceability records which locations that the product and lot number were transferred to. Each problem or situation is different and may or may not warrant an expanded scope. The distributor should notify the processor about the problem.
If a potentially unsafe product has been sold then the appropriate regulatory agency must be notified. For meat and poultry problems this would be the Food Safety and Inspection Service at the USDA and the FDA for all other problems. Canada has its own agency called Canadian Food Inspection Agency.
Retailers, Distributors, Processors, Raw & Packaging Suppliers need to work together to determine the source of the problem as quickly as possible. Utilize the traceability records to backward trace and review each step for potential sources. The traceability module in Ramco Food and Beverage ERP quickly facilitates this to provide a list of production/batch run dates/times, input lot numbers, and quantities. Locating the source of the problem is critical to limiting the scope of the recall and will require collaboration, transparency, and support. The better the granularity of the traceability data the more refined the scope of recall can be. Of course, cost tradeoffs on the number of transactions and potential recall scope need to be considered.
Once the source is identified move ahead with a forward trace to identify all products, lots, shipments, and customers potentially affected. This is the scope of the recall. All product directly within control should be immediately quarantined for future review by the recall team.
Each of the affected customers must be notified. For producers, this will include distributors or direct store delivery (DSD) customers. For distributors, this will include retail locations. For retailers, they will immediately pull any remaining product from the shelves and work with local press and agencies to attempt to notify local customers. An integrated CRM system can facilitate the communication process via integrated outbound emails and call lists for direct follow up.
Upon completing customer notifications attention turns to product control, analysis, and disposal. Ensure liability insurance covers the costs of disposal downstream in the supply chain.
Once the product has been secured and disposed of turn your attention to where the food safety controls broke down, identify improved control points and procedures, and improve your program.
Conduct mock recalls on a regular basis so that in the event of a recall you are well positioned and not inventing it as you go.