There have been a number of highly publicized food recalls in the food industry in the last few years. From polony to pilchards to juice, major food manufacturers have had to undertake public recalls under the watchful eye of the media and several government departments.
Food recalls are expensive activities but besides the real costs, the hidden costs of brand reputation and lost sales can be crippling. This is something you need to ensure works as smoothly as possible to avoid panic in the market and instills consumer confidence rather than shatters this. Our advice – avoid having to do a recall at all costs by ensuring your food safety management system works effectively to prevent one!
At Food Focus, we always view a recall as a positive action – we promote this act as a brave and responsible action on the part of the manufacturer (That is why you should send us your recall notices so we can help share them with our audience).
But this process does require effective planning and control on your part.
Here is a 7 step plan for an effective recall:
1. Write a detailed recall procedure
This is a critical document as during a recall you do not want to be making it up as you go along. All food safety standards require you to write one, but the trick is whether you have written it correctly.
2. Practice regular mock recalls with a variety of possible scenarios
Make sure you practice trace forward – the fate of a whole lot or batch to customers and trace backward to suppliers. Also, ensure you can account for all affected product and not just the selected batch – if an ingredient was affected you would need to find all the product where that ingredient was incorporated. Make sure you time the exercise strictly and give feedback. Update the procedures based on what you learn.
3. For a real recall, contact your lawyer first then your insurance company
Both professionals will assist you in negotiating the process so that you are not in breach of legal requirements or your insurance cover. They have done it before, and this may be your first time.
4. Contact the National Consumer Commission
The Consumer Protection Act requires that voluntary recalls are notifiable where the reason for the recall is safety-related. You need to contact the National Consumer Commission in this regard
Ms. Prudence Moilwa (Divisional Head: Enforcement and Investigations) and she will involve the Investigations Department. There is a form to be completed (which published under the recall guidelines) and documentation to be submitted, Ms. Moilwa will advise on this.
The forms can be downloaded here:
https://www.thencc.gov.za/sites/default/files/u2/Complaint%20Form%20%202018.docx
5. Contact the NRCS and DOH
If you produce a product that is manufactured under a compulsory product specification as in the case of the recent pilchards recall, the NRCS must be informed. For all food related products, the National Food Control department must be contacted and your local Environmental Health Practioner. This is critically important as port health may have to be alerted for exported products.
Environmental Health Department Contacts
We have a list of some of these on our website, you should find your area listed there:
http://www.foodfocus.co.za/home/Industry-Topics/food-safety/Environmental-Health-Department-Contacts
Penny Campbell:
Email: penny.campbell@health.gov.za
6. Make sure there is ONE channel of communication in all cases
Given the crisis and the potential consumer panic, it is paramount that all communication is clear, concise, and correct. This is not the time for indecisiveness and a lot of empathy is required. Think like a consumer – not a scientist or accountant at this point. If you react confidently and positively, research shows that most consumers will continue to support your brand.
7. If in doubt rather recall
To recall or not to recall can be a watershed moment for your organisation. Get it wrong and you can kill your brand. Get it right and protect lives AND your brand. Don’t forget the impact on the food safety culture of your business too. Top management taking the right action in this situation speaks volumes to your staff about what you REALLY believe when it comes to food safety.
And remember, share your recall notices with us so that
we can help you inform the public - it's the right thing to do!
