Your business needs a product recall plan!
In times of uncertainty, knowing that the rest of 2020 will be “virtual” allows us to develop professionally on issues that we do not know or about which we know very little.
That is why in this issue, I decided to focus on Food Safety and ask you: Do you know what it takes to execute a product recall to protect public health, comply with all government requirements and minimize the impact on your deal?
I didn’t know it, but when you work in the agri-food industry, it is advisable to seek advice and training as much as possible. Here are the basics to know:
What is a product recall plan?
A product recall plan provides specific procedures, defines terms, and assigns roles and responsibilities when a food safety problem arises with a food product. It can also be used for quality problems. In addition to operational roles and responsibilities, it should also include internal and external recall communication activities.
The food safety plan
The food safety plan sets out the steps an operation takes to avoid a recall and may include items such as training, sanitation, handling of raw materials, testing, etc. If the potentially contaminated product reaches the market, the recall plan guides the company through the response and recovery from this event.
Traceability procedures
Clearly understanding what happened to the affected products, to whom it was shipped, and in what quantities is critical. However, that constitutes a small part of the recall plan. The retirement plan is primarily about decision making and communication. Who decides if a withdrawal is needed? What do you tell your customers, and when? How do you interact with regulators? The retirement plan is much broader than a traceability plan.
Why does my business need a product recall plan?
It is required if the company is under the Preventive Controls for Human Food rule.
If the hazard analysis within the food safety plan identifies a risk that requires preventive control, FDA requires the facility to have a written recall plan that contains procedures and assignments of responsibility for the following:
- Directly notify the direct recipients of the food being recalled.
- Notify the consumer when appropriate to protect public health.
- Carry out effectiveness checks to verify that the withdrawal is carried out.
- Properly dispose of recalled foods.
- Having well-thought-out action plans in a document allows quick and effective reactions by key stakeholders to minimize both exposures to consumer health risk and liability risk to the company.
- In today’s business environment, it is often considered part of the fiduciary duty of the owner or the Board of Directors.
- Being prepared to handle the unexpected gives your employees and customers confidence in the company as an employer and supplier.
10 key components of a product recall plan
- Recover equipment, including substitutes for each team member.
- Roles and responsibilities for each team member throughout the recall response process.
- A list of questions to ask before making a decision to recall a product.
- Clear direction on when an event should be reported on the Reportable Food Registry.
- Document the process for informing employees, in multiple languages where appropriate.
- How to communicate with customers who received the recalled product (and who will be responsible for this activity).
- An established process and a person assigned responsibility and to track and monitor the effectiveness of the withdrawal (how will you demonstrate that customers received your withdrawal notice and acted on this?)
- How and what to communicate to consumers about the recalled product (and who will be responsible for this activity).
- Product disposition process and person responsible for carrying it out.
- Written procedures on how to handle an inspection by federal and/or state authorities after the recall.
If you would like to train on this subject, the United Fresh Produce Association will be offering a virtual “Recall Ready” webinar on September 10-11. For this and other training visit https://www.unitedfresh.org/events-programs/calendar-events/
