Fresh Focus: Call an Audible When a Recall Occurs

So you think you’re ready for a product recall? You’ve probably conducted annual mock recalls over the years and have a written plan that the auditors look at when they’re in town. I bet you’ve even conducted a “paper trail” traceback exercise for customers in the past.

But I would wager you are not ready for a real recall. When that happens, it’s time to “call an audible,” as they say in football. (In watching the playoffs, I learned you “call an audible” when you aren’t prepared for the other team’s set-up.) Practice might make perfect, but some situations call for a change in mid-stride.

Just ask anyone at Earthbound Farms – the apex of the spinach recall in 2006. I heard Will Daniels, vice president of food safety, speak several months ago and I got worried – for the industry and for our clients. I know where many of you stand with your recall plan – it has been written and tested, but probably not by the real thing.

Now is a perfect time to put down the phone, ignore the e-mail and focus on preparing your staff for a recall. My recent risk analysis using outbreak data shows there has been a measurable increase in scrutiny of fresh produce products in the search for outbreak sources. It is time for processors to identify some new tactics in preparing for a recall.

The Interception

An outbreak interception can come slamming into your corporate office with high speed at any time and land right in your lap. For instance, you probably couldn’t handle the sheer number of phone calls associated with a public recall. But did you know you can hire an outside company to answer the calls, take notes and get basic messages out to the public? Now is the time to research who these companies are, what they charge and how they provide services. Management can then be available during a crisis to focus on priorities like researching the problem, coordinating product disposal and general communications.

Nothing in your plan can prepare you for the magnitude of the questions and number of inspectors that will swarm your offices if a public outbreak is associated with your product. Management will be shooting from the hip and “calling audibles” for days if caught off guard. If you aren’t prepared for the interception today, planning can help. Below are some things to consider if you want to put your company in a better position than others have endured during a real recall.

Put the Team to Work

First, insert your product recall plan within an overarching crisis management plan. This will encompass public relations (PR), legal, insurance and other team players you might not include in the product recall plan. I think PR is one of the most important subjects to prepare for since most companies do not have this area adequately staffed. All the companies that call Edith Garrett & Associates in a crisis ask for PR help, so this is a universal need.

Second, prepare your strategy for handling documents while the investigators are in the house. Work with your legal adviser while it is quiet and calm to outline your strategy for handling records, because this may be the make-it-or-break-it step in the process that creates a smooth experience. Decide what to do about pictures in the plant, as well.

Being more open with your records will expedite the process once investigators arrive at the plant. It will make them feel you are a team player in the investigation, making their job easier. But it is imperative that you decide now what is proprietary and what can be shared with the world. Determine what you can share freely without jeopardizing your process, because all documentation will become public record when investigators get back to the office.

Third, research the costs incurred by other companies in a recall situation to get a feel for a budget, because unforeseen costs are sure to be a distraction during a crisis. For instance, several of our sources recommend covering the health care costs of any victims in a foodborne illness outbreak, right from the beginning. Researching that decision when all is calm will prepare you to plan for the event.

Watch the Replays

Once the exercise is over, outline your weak points and gaps in information. A good planning session will end with a final report and checklist for those items missing or in need of attention. Take the time to upgrade current practices to include some of the steps you find important. Training will probably be one area that needs attention, so find an expert who can bring your team new strategies.
Finally, form a food safety team if one does not exist today. Use the team to create an environment of “preparedness” in the company, to instill confidence. A cooperative team approach can organize the files and get the employees to be better prepared for an influx of inspectors. If you can score well on an unannounced third-party audit, then you are on the way to being inspection-ready.




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