Planning For A Product Recall

In developing and executing a plan in the event of a recall, there is a sequence companies should follow, says United Fresh Produce Association's David Gombas. The steps are as follows:

A. First, take it seriously. If top management thinks this is just an exercise and it will never happen to them, then no one else will take it seriously, either. Unless the highest level of management believes crisis preparation is important, skip the rest of this and just hope for the best.

B. Assemble a recall team. The team should include:

i. The company president or highest authority for the company or at least the highest authority on site. Some companies make the mistake of thinking that the head of Quality Assurance or Food Safety is sufficient. In the event of a recall, business decisions will have to be made quickly and may affect the future of the company.

ii. Someone who knows all of the operation’s Quality Assurance or Food Safety activities, knows where the QA records are, and can quickly get QA information about any product lot in question.

iii. Someone who knows all the operations, knows where the production records are, and can quickly get production details about any product lot in question.

iv. Someone who can track the product quickly — when was it harvested, who was it shipped to, when and how much. That person will need to access records that identify where all of it went, not just most of it.

v. Sales; chances are that customers will have to be contacted, and product deliveries may have to be delayed or cancelled.

vi. Legal counsel; someone who knows the company’s legal and regulatory rights and obligations in the event of a recall.

vii. A communications specialist; someone who knows what messages will be needed and how to write them.

There may be more, depending on the incident, but this is the minimum. In large operations, each of these may be different departments. In small operations, it may be just the two of you. If an operation doesn’t have these resources in house, identify outside sources, get them to participate in developing and practicing the plan (see more about practicing below), and get their cell numbers. Recalls always happen at the worst times. If getting outside resources (e.g., legal or communications), make sure they’ve worked on produce recalls before; you don’t want someone “learning how” during your recall.

C.Get training. I was tempted to write out all the things a team needs to consider in developing a plan, but that would take pages and still wouldn’t provide enough information. The United Fresh course Training for a Recall, Communicating Under Fire spends a full day on what a team needs to know.

D. Write the plan. Who will get the product lot and traceability information? Who will communicate with government officials? Who will communicate with customers? Who will communicate with employees? Who will decide whether the facts are sufficient and accurate, and whether and when to declare a recall? Who will be the backup in case someone on the team is not available?

E. Practice the plan. Imagine scenarios that could lead to a recall, and practice them. Don’t be easy on yourself; real situations won’t be. Get the product records and verify the ability to track 100% of it, verify customer and government contact information is current, write the press releases and practice media interviews. My advice: don’t warn the team in advance, just do it — that’s how a recall will happen. If a key member of the team is on vacation during the mock recall, practice dealing with it. And practice the plan often enough that the team knows what they’re doing, and then at least annually after that.

F. Fix the plan. After every mock recall, the team should meet, review what happened and decide how to do it better.

It is important to develop and execute a plan in the event of a recall.