The reasoning behind conducting mock product recalls

March 10, 2017

Despite increased efforts and innovations in food safety procedures, more than 600 food recalls happened last year, and the produce industry was not exempt from the alleged allergen or bacteria contamination that occurred.

For instance, this past May, CRF Frozen Foods voluntarily recalled all of its organic and traditional frozen vegetable and fruit products processed in its Pasco, Washington, facility since May 2014, due to a possible listeria contamination. Due to this recall, many other companies have recalled hundreds of other products sold under dozens of brand names.

The good news is, there’s plenty that can be done to prepare for a possible recall; it all comes down to training employees properly and conducting a substantial mock recall to learn what the company is doing right – or more importantly, where a company is going wrong.

Roger Roeth, executive technical officer for EAGLE Certification Group, Dayton, Ohio, likes to use a football analogy in explaining the importance of a mock recall: “You have a team, you develop a game plan and you practice it to make sure you have a winning plan and everyone understands their role and responsibility,” he said. “Without the practice, it could be chaotic.”

The United Fresh Produce Association offers a Recall Ready Workshop designed to help companies prepare for an unexpected recall event.

“Within the produce world in particular, given that many of our members produce raw products grown often outside, there is a chance, despite our best efforts, that at some point something could go wrong and a company may need to execute an actual recall,” said Jennifer McEntire, vice president of safety and technology for United. “To have the practice of going through a mock recall to understand the complexity and multitude of issues you will be faced with in the event of a recall is vital. After all, it is way better to get that experience in a safe practice environment than in real life when you are in the thick of it.”

Companies define mock recalls differently. Some will do very minimal mock recalls or just some of the very specific components individually. There are many ways and avenues to go down when doing a recall. Erin Grether, United’s manager of grassroots coalitions, notes it’s really up to each company to decide what they want to test, how much time they want to spend, the resources they want to put into it and the areas of their system they want to test to make sure they are well developed and well understood so if there is a real event, it can go as smoothly as possible.

“We offer full-scale simulations to our members, where we act out a simulated real-life event that would include the communications pieces, the legal pieces, the regulatory pieces, as well as the scientific aspects associated with the recall, including instructing people on what to do with the product, how to dispose of the product and insurance issues,” Grether said. “We have a suite of services that includes company-specific recalls and we provide a recall-ready workshop, open to anyone who wants to attend, to go through an actual real-life simulation with a team.”

At the workshop, an FDA speaker will come in, McEntire will talk about the risks of a recall and how to prepare, an attorney will talk about the legal applications, and a communications expert will take attendees through the communications aspect of it all, including press releases and handling consumer calls.

“We also offer a recall plan review, where a company provides a document of their recall plan to us and the team will go through it and will provide a written report and feedback and do calls with them to tell them how to improve their plan,” Grether said. “We can also help build a recall plan for a customer who may not have one already. For this, we go to their company, meet with some of the folks there and build the plan.”

Additionally, United has a one-day executive management workshop that gets the top leaders of a company ready for a recall, and has a two-day on-site training program, complete with fake reporters and fake social media posts to see how employees respond with their plan.

When performing a mock recall, Roeth suggests you go through the written plan exactly, as if it was a real- life scenario.

“Follow line item by line item, and look at what you need to do, how to do the exercise, how to communicate to customers and regulatory, and have someone be a scribe and document what was being done so when you go to review your plan that you can see step by step how your team managed the plan and performed,” he said. “At the end of the exercise, evaluate your activity and see what went well, what did not go well, and if it was really bad, do another one a month later and take care of the issues.”

He also said a company should develop a template to document the exercise, as it not only gives you a list of what you need to do but also provides evidence that company can show the auditor that it performed the exercise.

Everyone makes mistakes

The No. 1 mistake Roeth sees is that companies do a trace exercise instead of a full mock recall, and think that’s enough.

“In the old days, before the GFSI standards, companies would find the product and trace forward but didn’t get into a plan or know who was doing what activity. That was the whole extent,” he said. “When people do that, they
don’t do the other aspects of a mock recall.”

Other mistakes he sees include having only one or two people involved in the recall preparation instead of the entire team, and not documenting the activity properly so when an auditor goes in, he or she doesn’t see any evidence
that they’ve done anything.

McEntire notes one of the key mistakes that people make is underestimating the frenzy that could ensue, and the number of key inquiries and different directions they may be getting pulled into during the chaos.

“Sometimes, what I have seen is that it illustrates the lack of clarity in the recall plan around decision making,” she said. “When it happens, people need to be prepared for who has what information at what point in time and who’s making the decisions.”

Grether said that often people aren’t prepared for a recall, and many employees think it falls on the food safety person, but everyone on the team needs to play a role, from communications to the front office to those answering the phone.

How often is a mock recall needed?

From a regulatory standpoint, there is a requirement for a written recall plan, but a mock recall isn’t required – although some people’s auditors have requirements for a mock test.

“Once a year is what people aim for, but some people do it more often depending on how the first one goes,” McEntire said. “Maybe they found their systems are not up to snuff and they want to make those improvements and see if they had an impact.”

Plus, people change within companies and roles change, so companies should pay close attention to the environment and make sure everyone stays prepared.

“One thing a company should do before a mock recall is determine if they want it to be announced or unannounced,” Roeth said. “Some companies will do two mock recalls a year, and one is announced and one isn’t.”

— Keith Loria, contributing writer


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