Food safety expert, Ron Wasik, offers an overview of approaches to enhance food recall effectiveness
An article on recall effectiveness in Canada published in the May/June 2017 edition of Food Protection Trends magazine and authored by Carly Winters, Anne Wilcock and Jeff Farber of the University of Guelph, will be of interest to everyone in our industry. Here is what I took away from the article.
The authors interviewed nine individuals, six from industry and three from government, to learn their perspectives of “what constitutes an effective recall within the Canadian context.” Those interviewed reinforced the importance of doing the basics, but also came up with a number of new approaches to enhance recall effectiveness.
Here’s a short list of the recall basics that were mentioned in the article, along with some of my own comments:
1. Have a plan – Having a written recall plan in place is the first step in the process of recall preparedness. Any plan is better than none. The CFIA’s website provides a detailed template that I have often referenced (www.inspection.gc.ca).
2. Work the plan – A recall plan that is not rehearsed at least once a year loses a lot of the benefits of having a plan. The more time invested in working (testing) the plan, the more effective it will be in a crisis.
3. Update the plan – Every plan should be audited at least once a year to ensure that the contact information, the roles and the responsibilities of the recall team members are up to date. Any learnings from industry and government, as well as from mock and actual recalls, should be used to improve the plan.
There were also a number of insightful ideas shared by those interviewed:
1. Be responsible – Customers are more likely to forgive you if they believe that your company is acting responsibly to address the problem.
2. The message – Getting the recall message right is critical to getting results and mitigating long-term damage.
3. Point of sale notices – Placing recall notices at the place where the product is purchased has proven to be one of the most effective ways to notify consumers of a recall.
4. Traceability – Knowing where your product is located significantly improves both the speed of recovery and the quantity recovered. Knowing the sources of the ingredients used to make the recalled product can also be important. One issue that frequently complicates recalls is poorly defined product lots. If
regulators believe that there isn’t a clean separation between the recalled product and other lots, they will expand the quantity and number of products to be recalled in order to err on the side of caution.
5. Unannounced CFIA-initiated mock recalls – Unlike today’s announced CFIA or planned company recalls, unannounced CFIA-initiated mock recalls should come at any time. This would be a more accurate test of a company’s recall and traceability programs.
6. Risk assessment – Currently Health Canada does a risk assessment, and based on that assessment the CFIA will determine if a recall is warranted and, if warranted, assign a category (one, two or three). More consideration should be given to sharing a version of the risk assessment with the company involved in the recall. Greater transparency and dialogue between Health Canada, the agency and the producer at this stage would benefit both parties.
7. CFIA recall co-ordinators – Currently CFIA recall co-ordinators handling a recall are assigned the case based on their availability, but not their knowledge of the recalled product in question. Co-ordinator assignments should consider the person’s experience and knowledge of the product category.
8. Technology – The CFIA and Health Canada should have the same management information systems to improve communication. These systems need to be accessible to all employees in both organizations that deal with emergency response.
9. Food safety culture – Firms with a strong food safety culture, in which all employees are held to the same food safety standards, have fewer recalls.
I strongly encourage readers to access the entire article for all of the insights and recommendations in this publication. For International Association for Food Protection members, it can be downloaded at https://www.foodprotection.org/members/food-protection-trends/
Dr. R.J. (Ron) Wasik, PhD, MBA, CFS, is president of RJW Consulting Canada Ltd. Contact him at [email protected]