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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:
- Unclear decision-making authority. Recall plans often identify the food safety/quality assurance staff as the “recall coordinator.” But when customers or the government asks if you will issue a recall, who makes the ultimate decision? And what if that person is on a week-long vacation with no cell service? (Yes, that actually happened once.) Who participates in the discussion? What if there isn’t consensus within the company? Are outside experts consulted?
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?
- Having a plan isn’t enough. Finally, the greatest challenge to effectively and efficiently carrying out a recall is lack of planning, or increasingly, the lack of familiarity with the plan. Driven by investors, regulations, or awareness, more companies seem to have recall plans, but in most cases, plans sit on shelves and are never updated, tested, or used — even when there is a recall. No company wants to issue a recall often enough to get good at it; but being good at it could save the company. So, practice. Conduct an annual recall simulation and make it as real as possible: go beyond the trace exercise, include communications, test the plan, and involve every major business function in the company.
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:
- Equipment. One of the most frequent areas of infestations is within the equipment, as it has many nooks and crannies that provide ideal temperatures, humidity, and food supply to help pest populations flourish. Consider replacing metal cover cleaner plates with plexiglass to allow for easier inspection without having to disassemble equipment.
- Plumbing. Cockroaches prefer warm, moist, dark environments, and often enter structures through floor drains and utility pipes. Flies are similarly attracted to sinks, floor drains, and bathrooms, so these areas should be cleaned on a regular basis to prevent moisture and debris buildup that could be conducive to an infestation.
- Storage Areas. Proper storage and stock rotation are essential in preventing an infestation. All items should be stored up off the floor on pallets and at least 18 inches from walls to create an aisle, making pest inspections easier to conduct. Also consider painting the aisle white so that pests and their droppings are easily visible.
- Entry Points. Mice can fit through a hole the size of a dime and rodents through a hole the size of a quarter, so it’s imperative to seal any cracks or crevices in the structure, including entry points for utilities and pipes, with silicone caulk and steel wool. Institute a “no-prop” door policy, and install air curtains or screens to keep flying insects out.
- Waste Management. Ensure the facility has an adequate waste management system in place. Garbage should be stored in sealed containers at all times and disposed of on a regular basis. If there is a dumpster on the property, it should be kept away from entryways, have a working lid that remains closed, and be emptied regularly.
- Landscaping. Vegetation that is too close to the building can attract pests, increasing the likelihood that they will find their way inside. To prevent this, install a gravel or rock perimeter to discourage vegetative growth that could invite and harbor pests.
- Proper Drainage. Many pests are attracted to moisture, so make sure the building has proper drainage at its foundation to prevent moisture buildup. This includes installing downspouts, gutters and diverts to channel water away from the building and ensure excess water doesn’t accumulate.
- Lighting. Lighting plays a key role in either attracting or discouraging pests from setting upon a facility. Sodium vapor lights are the least attractive to pests and should be installed as far from the building as possible. Conversely, mercury-vapor lights are very attractive to pests and should not be used within 150 feet of any food processing facility.
- Structural Integrity. Repair fascia, soffits, and rotted roof shingles, as some insects are drawn to deteriorating wood. Replace weather-stripping and repair loose mortar around the building’s foundation and windows, as these also could serve as entry points if damaged or decaying.
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.