How To Handle A Recall

The editors of American/Western Fruit Grower asked David Gombas, senior vice president, food safety and technology for United Fresh Produce Association, to share some tips on how growers can survive and overcome involvement in a product recall. Here are his thoughts:

Q: If a grower is involved in a recall, what is the first thing he/she should do?

A: In the event of a recall, the first thing growers should do is implement their recall plan. Of course, that means they need to have one to implement, which means that waiting for a recall to become prepared is far too late. Trying to handle a recall without a plan is like deciding to run a marathon without any training. Companies can survive a recall if they are unprepared, but it will always be more painful, emotional, and costly than if a company is prepared. And, without preparation, a company is far more likely to make a costly or even fatal mistake while handling the recall.

  • for a list of steps to take in developing and executing a recall plan.

Q: Should the recall be handled differently depending on if it’s Class I, II, or III?

A: The first question should be, “Is this a recall, a product withdrawal, or a stock recovery?” FDA provides some guidance on this on their Web page. If the product is still completely in a company’s control, it’s a “stock recovery” and no recall is needed. A “product withdrawal” occurs when a product has a minor violation that would not be subject to FDA legal action. If a product has already changed hands and left the company’s control, but there’s no evidence (at most, only a suspicion) that the product is actually adulterated, then the product may be “withdrawn.” If there is evidence of adulteration (even if the evidence is found after a product is withdrawn), and the product may be in consumers’ hands, then it’s a recall. If the affected product hasn’t reached consumers yet, getting control of it and stopping it from going any farther can make all the difference in what happens next.

Recall classifications are decided by FDA, and often after the recall has been initiated. By the time a recall team calls the FDA Regional Recall Coordinator, they should have all of their facts in line, know where all of the affected product is and how to get it back, and, if it’s a food safety issue, have a press release ready to go. And all of this should happen within the first 24 hours. The recall team should want FDA to have confidence that the company knows what it’s doing and is doing it well.

After the FDA Regional Recall Coordinator is contacted, a company should expect that FDA or state agency investigators will be visiting soon. The government’s job is to make sure that the company is handling product safety as completely and as competently as it should. The company’s job is to demonstrate to the government investigators that it is. A company should be able to convince the investigators that it has taken the issue seriously, has investigated it aggressively, and is implementing effective corrective actions to reduce the risk of the issue happening again.

Q: What resources are out there to help growers if they are involved in a recall?

A: FDA provides recall guidance to the industry, including model press release letters, at www.fda.gov/Safety/Recalls/IndustryGuidance/default.htm.

United Fresh offers a service to member companies during a crisis. We will work with a member’s recall team to review the evidence of the contamination, to review and provide advice on their recall plan, even work with them on communications. We don’t replace their recall team or write their recall plan, but we do provide a “sounding board” to help a company avoid the most common mistakes.

Q: Is there anything you’d like to add?

A: A company doesn’t have to do anything wrong to be caught in a recall situation. I’ve worked with many companies in these situations, and every one has been shocked to hear that a product they’ve handled might be contaminated. Many companies don’t survive a recall even if they are prepared; but fortune favors the prepared.

Last September, FDA created a new Reportable Food Registry. Any company that has evidence that an ingredient or product they’ve handled is adulterated, i.e., “a food or feed that may cause severe health consequences or death to humans or animals,” is legally obligated to report it to FDA through the RFR portal. Currently, farms are exempt and only companies that are required to have registered with FDA are required to comply, but growers should become familiar with the RFR nevertheless (www.fda.gov/Food/FoodSafety/FoodSafetyPrograms/RFR/default.htm). Experience has shown that, if a packinghouse or subsequent customer reports a produce item in the RFR, the grower will almost always be included in the investigation.

There’s a mistaken perception that if a product has passed its use by or shelflife date, then no recall is necessary. Not so. If FDA thinks there is any reasonable chance that a contaminated product is still in consumers’ hands, even in a consumer’s freezer, they will very likely request a recall.

Knowing when to pull the trigger on a recall is one of the most difficult decisions a recall team will have to make. Too late, and you may have put more consumers at risk. Too soon, and the recall may not have been necessary and you’ve created unnecessary liability and costs, in dollars and to your company’s reputation.

For a list of steps to take in developing and executing a recall plan,

Leave a Reply

Featured Stories
Crop Protection
July 23, 2017
USDA Invests $7.6 Million toward Beneficial Research
Projects to promote beneficial organisms as part of a pest control strategy. Read More
Citrus
July 22, 2017
Representative from Washington Proposes Amendment to H-2A Program
Move broadens use of H-2A to all of agriculture to include those with multiple crops and harvests. Read More
Insect & Disease Update
July 21, 2017
University of California Launches Website to Update Growers on Citrus Research
Easy-to-read format designed to give growers up-to-date information on huanglongbing and Asian citrus psyllid research. Read More
Hurricane Matthew satellite image as it brushed past Florida
Citrus
July 20, 2017
Atlantic Hurricane Forecast Taken Up a Notch
Current conditions in the tropics warrant marked revision in potential storm season scenarios. Read More
Sunset on Florida potato field day
Citrus
July 19, 2017
Researchers On a Mission to Find More Places for Growing Produce
Federal grant to aid exploration of food security solutions for the future. Read More
Citrus
July 19, 2017
Farm Labor Stories Making the News This Week
The agricultural labor shortage is strong enough that the consumer press is beginning to report on it regularly. Here are the stories making headlines this month. Read More
Sweet Corn
July 19, 2017
Variety Specs | Production Tips: Corn ‘Anthem XR’ from Rispens Seeds
Each month, American Vegetable Grower® will offer growing tips on specific varieties, supplied by the breeder or distributor. This month, we’re offering Read More
farm hacks collage
Citrus
July 19, 2017
Florida Grower Magazine is Seeking Your Farm Hacks
Life hacks are common in social media threads these days. They are those clever ideas or tricks aimed at making Read More
Organic
July 19, 2017
4 Challenges Large Operations Face in Organic Vegetable Production
Organic vegetable production in Monterey County has evolved over the past 25 years. It was once the domain of small- Read More
Farm Management
July 19, 2017
Tom Nunes, V: The Best Labor Solutions Are When Everyone Wins
Competition for skilled farm labor is fierce in the West. But Nunes Vegetables, Inc. believes when growers work together, they will attract more workers to their community. Read More
Fruits
July 14, 2017
Brown Marmorated Stink Bug Predator Egg Mass Found
Samuri wasp parasitized egg mass found in Southern New Jersey peach orchard. Read More
Rain drops on leaf
Citrus
July 14, 2017
Everglades Agricultural Area Farmers Winning at Water Quality
Annual report shows use of best management practices results in another massive reduction in phosphorus flow. Read More
cut watermelon
Cucurbits
July 13, 2017
Scientists Keying in on Sweeter and Stronger Watermelon Varieties
New study shows grafting can give growers an upper hand on soilborne disease threats. Read More
Citrus
July 13, 2017
The Road is Long to Farm Bill 2018 [Opinion]
Participation in this process will be crucial to ensure your needs are understood and addressed. Read More
2015 FFVA Annual Convention crowd
Citrus
July 13, 2017
Trade Talk to Top Florida Fruit & Vegetable Association Convention Agenda
Trade issues are top of mind these days for specialty crop producers. Efforts have been underway since early this year Read More
The Latest
Crop Protection
July 23, 2017
USDA Invests $7.6 Million toward Benefic…
Projects to promote beneficial organisms as part of a pest control strategy. Read More
Citrus
July 22, 2017
Representative from Washington Proposes …
Move broadens use of H-2A to all of agriculture to include those with multiple crops and harvests. Read More
Insect & Disease Update
July 21, 2017
University of California Launches Websit…
Easy-to-read format designed to give growers up-to-date information on huanglongbing and Asian citrus psyllid research. Read More
Citrus
July 20, 2017
Atlantic Hurricane Forecast Taken Up a N…
Current conditions in the tropics warrant marked revision in potential storm season scenarios. Read More
Citrus
July 19, 2017
Researchers On a Mission to Find More Pl…
Federal grant to aid exploration of food security solutions for the future. Read More
Citrus
July 19, 2017
Farm Labor Stories Making the News This …
The agricultural labor shortage is strong enough that the consumer press is beginning to report on it regularly. Here are the stories making headlines this month. Read More
Sweet Corn
July 19, 2017
Variety Specs | Production Tips: Corn &#…
Each month, American Vegetable Grower® will offer growing tips on specific varieties, supplied by the breeder or distributor. This month, we’re offering Read More
Citrus
July 19, 2017
Florida Grower Magazine is Seeking Your …
Life hacks are common in social media threads these days. They are those clever ideas or tricks aimed at making Read More
Organic
July 19, 2017
4 Challenges Large Operations Face in Or…
Organic vegetable production in Monterey County has evolved over the past 25 years. It was once the domain of small- Read More
Farm Management
July 19, 2017
Tom Nunes, V: The Best Labor Solutions A…
Competition for skilled farm labor is fierce in the West. But Nunes Vegetables, Inc. believes when growers work together, they will attract more workers to their community. Read More
Fruits
July 14, 2017
Brown Marmorated Stink Bug Predator Egg …
Samuri wasp parasitized egg mass found in Southern New Jersey peach orchard. Read More
Citrus
July 14, 2017
Everglades Agricultural Area Farmers Win…
Annual report shows use of best management practices results in another massive reduction in phosphorus flow. Read More
Cucurbits
July 13, 2017
Scientists Keying in on Sweeter and Stro…
New study shows grafting can give growers an upper hand on soilborne disease threats. Read More
Citrus
July 13, 2017
The Road is Long to Farm Bill 2018 [Opin…
Participation in this process will be crucial to ensure your needs are understood and addressed. Read More
Citrus
July 13, 2017
Trade Talk to Top Florida Fruit & Ve…
Trade issues are top of mind these days for specialty crop producers. Efforts have been underway since early this year Read More
Citrus
July 12, 2017
Shaky Florida Citrus Season Skids to a S…
Final USDA tally confirms continuing downward trend of production in the HLB era. Read More
Citrus Achievement Award
July 12, 2017
Encourage New Citrus Growth by Getting B…
2017 Florida Grower Citrus Achievement Award winner Ed Pines says producing crops under protective screen is a way to farm more and stress less. Read More
Citrus
July 12, 2017
Tomato Pests Can Be Induced to Cannibali…
The University of Wisconsin's John Orrock says when beet armyworms are exposed to concentrations of methyl jasmonate, they will abandon eating tomatoes — and start eating one another. Read More