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You assemble your recall team and conduct your mock recall every year, maybe more frequently. But if a real crisis strikes, what’s the chance that the mock recall exercise will have prepared you? Unfortunately for most companies, it’s slim to none.
Most mock recalls are really mock traceability exercises. But since they are not reflective of the outbreak investigation process, they are better described as exercises that show which lot numbers contained a certain ingredient, or the distribution path of a finished product.
In an actual recall event, the traceback and trace forward are often the least of a firm’s worries.
Following are the key challenges that we have observed from working with scores of companies involved in recalls or other food safety crises:
Difficulty in deciding how much to recall. Once the decision is made to recall, the next challenge is deciding how much to recall. If the recall stems from a product that tested positive, do you recall just that lot? How can you be sure the issue didn’t stem from raw material that could be present in multiple finished product lots (especially if the finished product lacks a kill step, like fresh produce)?
If the contaminant is Listeria monocytogenes, could it have been an environmental contaminant from your facility? Is it still there? Scoping the recall can be very challenging.
Too little, too late communication. The communications function often catches recalling companies flatfooted because they start thinking about it too late in the process. From the moment a potential issue is identified, begin preparing for both reactive and proactive communications. Identify the various internal and external audiences who may contact you and those with whom you may need to communicate. Remember, communication is two way, so prepare for not only issuing statements and messages, but also receiving questions and comments from employees, consumers, customers, boards of directors, regulators, and others. Monitor social media and online news sources, especially local ones. Have a holding statement that is used on an as-needed basis and which changes as you learn more.
For every communication task, identify the person or persons who will carry it out, how it will be carried out, and when. For example, most food companies have multiple customer contacts (food safety, buyers or purchasing agents, category managers, management, etc.). Which one(s) will you contact about a recall? Who will contact each one, when, and how? What will they say — exactly? What documentation do you need to demonstrate that you notified customers?
We could go on and on with examples of recalls gone wrong. While there will always be unanticipated twists and turns associated with an issue, you can absolutely prepare and practice the general process. Achieving regulatory compliance and passing an audit become secondary; when in crisis mode, true preparedness is what could make or break your company.
The new year is fast approaching, and many facility managers are hard at work developing strategies to make 2019 a success. While resolutions to be more productive and budget-conscious are imperative to the success of any business, a commitment to pest prevention is a resolution facility managers also need to make. Pests can cause widespread illness outbreaks, and coupled with poor sanitation, results can be disastrous. So, diligent pest control is one New Year’s resolution facility managers cannot afford to break.
Rodents present the biggest problem, as their droppings can transmit pathogens that cause diseases including Hantavirus and salmonellosis. The house fly can carry more than 100 kinds of disease-causing germs and moves from garbage and excrement to fresh food and other surfaces, contaminating processing equipment. Cockroaches are known to spread at least 33 kinds of bacteria, six kinds of parasitic worms, and at least seven other kinds of human pathogens, and they can pick up germs and debris on their legs and transfer them to food surfaces and processing equipment. Stored product pests can infest plant equipment and contaminate food by leaving body parts and cast skins which can get ground up into products or infest flour, grains, and cereals.
The best method of pest control in food processing facilities is Integrated Pest Management (IPM), whereby facility managers work with their pest control professional partners to inspect, identify, recommend, treat, and evaluate pest hot spots to prevent infestations. In addition to contacting a licensed pest control professional to inspect your facility, you can address the following nine hot spots now to get a jumpstart on your New Year’s resolution:
Pest management is most effective when conducted in partnership with a licensed pest control professional, but that doesn’t mean you have to wait for an inspection to enact pest-proofing measures that could protect your facility from an infestation. So, as you reflect on 2018 and make resolutions for 2019, be sure to add proactive pest management at the top of your list.
Anyone who has ever worked in or with food processing facilities knows that many of the tasks can be rote and become monotonous over time. And monotony can all-too-easily result in “shortcuts.” But a number of recent occurrences have shown the consequences of cutting corners at all levels of the food industry: from FDA’s newly released guidance on FSMA-granted authority to mandate recalls (https://bit.ly/2RYmgd3), the Interagency Food Safety Analytics Collaboration (IFSAC) foodborne illness source report, and the allergen contamination-related manslaughter convictions (https://bit.ly/2RYmgd3). As these show, the consequences can be extremely serious for a business and life-altering for individuals.
With FSMA’s new mandatory-recall authority, FDA can order the recall of a food if there is a reasonable probability that it is adulterated or misbranded and could cause serious illnesses or death. The rule does provide that the responsible party first be given the opportunity to do a voluntary recall, and at least two producers have taken the option to do so when they were served with the written notice of FDA’s intent. In addition to that partial use of its authority, FDA has used it once to its full extent, issuing a mandatory recall order in April 2018 for food products containing powdered kratom, after several were found to contain Salmonella.
On November 5, FDA released final guidance on the use of mandatory recalls. As noted in a statement from FDA Commissioner Scott Gottlieb M.D., the guidance is part of FDA efforts “to be as robust and transparent as possible and provide answers to questions that many have asked about the FDA’s mandatory recall processes. Our aim is to expand the appropriate use of our mandatory recall authority in cases where we have to intervene quickly to help protect consumers from unsafe products.”
That same week, the IFSAC report, “Foodborne Illness Source Attribution Estimates for 2016 for Salmonella, Escherichia coli O157, Listeria monocytogenes, and Campylobacter,” was released. According to the report, for which IFSAC analyzed data from just over 1,000 foodborne disease outbreaks from 1998-2016:
Attention to this report is important, not only for industry to increase its focus in these areas and ensure it is not cutting corners, but also because the report notes that the estimates may help shape agency priorities and support the development of regulations and performance standards and measures, and other activities. (Read the full report at https://www.cdc.gov/foodsafety/ifsac/pdf/P19-2016-report-TriAgency-508.pdf.)
While the recall mandate and IFSAC estimates are significant and serious, it is the mention of a manslaughter conviction for lack of allergen controls that likely most caught your attention. And if it didn’t, it should have.
Although it occurred in England, there’s nothing saying that such a judgment and conviction couldn’t, and won’t, be declared in the U.S., particularly because undeclared allergens continue to be a top cause for recalls by both FDA- and USDA-regulated facilities.
In the case, two food business managers in England were found guilty of manslaughter in the death of a 15-year-old girl who died after eating supposedly nut-free food from an Indian restaurant. The food was found to contain peanut protein to which she had a life-threatening allergy. The restaurant’s owner/chef and the take-out manager were convicted of manslaughter, not only because of the allergen presence, but because of the lack of food safety standards in the operation that could have prevented the teen’s death.
It can be tempting to take shortcuts, cut corners, and make allowances for “minor” mistakes here and there. But as these all show, there can be grave consequences to food safety concessions — both for your business and you, as an individual.