The outbreak of Listeriosis resulted in the largest food recall in South Africa. All media channels were flooded with notifications of the recall after the mandatory recall notice was issued on 4 March 2018. To make matters worse, the international sweetcorn recall again bombarded food service and retail sectors alike.
We have seen that recalls like these have a ripple effect on the food chain with retailers, distributors and other customers all having to implement a recall in their respective sectors. If your company was directly affected, you would have been dusting off your recall and crisis management procedure and implementing this. Hopefully it worked for you.
If you escaped this recall, the “near miss” should have prompted you to take the opportunity to review your current procedure to ensure that it would been effective in a real crisis. If you haven’t got a procedure, then now is the time to start thinking of one – this has just become a new legal requirements for all food handling establishments under the new hygiene regulations R638.
In my experience, many recall procedures have been written to tick an audit box but in reality, they are not worth the paper they are written on. Here are some of my best tips given my many years of dealing with food recalls in South Africa.
Every company should have a formal customer complaints procedure. The procedure should follow a logical flow and lead to escalation when a critical limited is reached or when a critical complaint is received for example a customer claiming food borne disease. It is important to note that when it comes to life threating issues - it is not a numbers game, one complaint can justify a full product recall. This procedure should clearly detail who should be notified in such a case.
Have you thought about where customers will lodge complaints? You should be monitoring or have monitored the following:
When you are receiving many complaints, the ability to track and review trends is critical and here you will need tools to help you:
When an issue is escalated, the Product Recall Team should perform a preliminary risk assessment. The team should be aware of what initial actions to take and who should make the appropriate decisions. This will include ensuring that appointed personnel have the authority to inform the relevant authorities.
It is imperative that all activities and decisions are entered in the Incident Log. The Incident Log will greatly assist the Product Recall Team to carry out the risk assessment process in order to determine if a product recall is required
Having a consistent way of recording the information provides a method to review information and this would serve as a legal document, should the need arise.
The Product recall team should use the following to determine if a recall is necessary:
NB: All these activities should happen simultaneously to enable the company to react in the quickest possible time – remember lives may be at risk. This is a critical activity and must be treated as such!
When considering what the budget is make sure you account for the costs to
You should have insurance in place for this scenario and your insurance company must be involved in the recall process. Remember the cost of the recall is far less than the potential damage to your brand.
If something is important, it should be written down and the same applies to your recall policy and procedure. The Product Recall Policy is an essential part of the food safety management system and should be developed and agreed before the Product Recall plan is even implemented. This demonstrates Senior Management’s commitment to protect public health and to provide resources to effectively manage a product recall. Putting the consumer’s health first is always the right thing to do.