Manage Recalls

• P1. Create an organizational chart and contact list outlining the members of the recall team.
• P2. Identify the roles and duties of each person; here is an example of roles and responsibilities shared among the recall team:
  • a. Top Management: decide if a recall should be launched, primary responsibility for handling the recall.
  • b. Food recall coordinator: track the recall activities.
  • c. Legal services: liaise with regulatory bodies and certification bodies.
  • d. Quality Assurance / Quality Control: trace product, determine the level of risk, determine the root cause of the problem, and take steps to fix it, liaise with certification bodies.
  • e. Operations: manage recalled products still under their control, manage returned products.
  • f. Procurement: liaise with suppliers.
  • g. Sales and customer services: liaise with clients.
  • h. Public relations: communicate with media and consumers.
  • i. Insurance broker: advise on coverages.
• P3. Identify members of the recall team.
• P4. Define roles and responsibilities of the suppliers, sources of technical advice and support (including laboratory facilities), vendors in handling recall situations.
• P5. Identify roles and responsibilities of various regulatory authorities at national and international level, as applicable, to handle recall situations.

• P1. Identify enterprise resource planning software management strategy for recall.
• P2. Create the documentation management system for production records.
• P3. Develop file management systems for invoices, bills of lading, purchase orders and other relevant records related to procurement and shipping.
• P4. Develop file management for batch and formulation records, and other records related to production and process control.
• P5. Develop sets of contact lists, including customer contacts, regulatory and food safety contacts, and supplier contacts for rapid communication.
• P6. Train supervisors and other staff in the use of the appropriate software and document management systems.

• P1. Design a decision tree to make a final decision on the necessity and extent of the product recall.
• P2. Write a recall procedure, defining the steps to follow:
  • – Assemble your recall management team.
  • – Determine the necessity to initiate a recall.
  • – If a recall is decided, then:
  • – Determine the level of the recall (for CFIA for example: Class 1, Class 2 or Class 3)
  • – Notify the regulatory authorities.
  • – Identify all food to be recalled.
  • – Hold and segregate food included in the recall that is still in your control.
  • – Prepare the distribution list.
  • – Prepare and send the notice of recall.
  • – Notify the employees.
  • – Verify and document the effectiveness of the recall.
  • – Control the recalled food.
  • – Decide what to do with the recalled food.
  • – Choose a corrective and preventive measure.
  • – Conduct a post recall review.
• P3. Notify all company officials.
• P4. Design the communication procedure to notify the inspection system and regulatory authorities; this includes but not limited to:
  • a. A detailed description of the nature of the problem
  • b. The food name, brand, size and lot code(s) or others
  • c. Label(s) of the food in question
  • d. The total quantity of food affected, and the quantity distributed.
  • e. Information on the geographical area of distribution of the affected food
  • f. When the food was distributed.
  • g. Whether the product has been sold to the final consumer
  • h. Details of complaints received and any reported illnesses.
  • i. Contact information of the staff member responsible for liaising with the regulatory authorities
  • j. The name, telephone number(s) and email address of the business’ after-hours contact
  • k. If the food is already being recalled, the communication with the inspection system will include the notice of recall, the distribution list, and the press release if applicable.
• P5. Review the relevant inspection public food recall warning.
• P6. Prepare the distribution list that identifies: each client’s name and address, the name, telephone and email address of each client, the type of client, and the amount of recalled food per lot code etc.
• P7. Communicate with insurance to evaluate potential recovery on inventory lost

• P1. Create mock recall scenarios that are relevant and realistic to the manufacturing operations and products.
• P2. Evaluate how the team performs a traceback mock recall exercise by selecting either a raw ingredient or other input needing recall.
• P3. Evaluate how the team performs a traceforward mock recall of a finished product by selecting a lot of finished products for the scenario.
• P4. Evaluate how the team identifies the product(s) lot(s) that have been affected by the recall.
• P5. Evaluate how the team identifies all customers who have purchased the product(s) in question.
• P6. Evaluate how the team uses the communication plan to contact customers who have purchased the affected product with mock recall, completes communications templates and requests for information.
• P7. Evaluate the efficiency of the recall in terms of time to complete the first outreach in the recall, and percentage of product reconciled with customers.

Managers have the responsibility to periodically verify the capacity of the recall plan for rapid identification and control of a the potentially affected product. They must reconcile the amount of product produced, in inventory and in distribution and identify correction of any deficiencies in the recall procedures. After conducting a recall or mock recall exercise, (mock or real), the managers must identify means to further develop and improve the current recall plan.

• P1. Measure the effectiveness of the current recall plan.
• P2. Evaluate time of completion of the recall.
• P3. Assess any problem identified during the recall implementation.
• P4. Amend the recall procedure to address any problems identified.
• P5. Evaluate quantity of affected product identified and rectified as a percent of total product produced.
• P6. Evaluate team performance when working under high stress and time pressure.
• P7. Evaluate effectiveness of communications tools, and communications modes.
• P8. Identify retraining and corrective action strategies for improving future recall performance.
• P9. Design other improvements in any other areas to prevent reoccurrence of the identified problems.
• P10. Improve the coding, marking or serialization of the products to ease the traceability across the end-to-end supply chain.
• P11. Conduct a root cause investigation to identify the source of the recall.
• P12. Implement corrective and preventive measures to fix the source of the recall.
• P13. Train the recall team how to follow and implement the recall procedure.

• P1. Define typical insurance policies for product loss and recall insurance.
• P2. Identify what is covered under the recall insurance, including costs of recall procedures, costs of replacing product, loss of profits, business interruption, rehabilitation expense, extortion costs (if applicable), crisis consulting and costs of brand management.
• P3. Evaluate the costs and benefits of having a recall insurance policy.
• P4. Justify the due diligence planning requirements to maintain a recall insurance policy (mock recalls, communications plans, organizational charts, customer databases, inventory, and production records).

• P1. Provide EI and soft skills training to members of the recall team.
• P2. Identify with the emotional stress of being in a recall procedure.
• P3. Regulate, handle emotions and stress, and react proactively to the situation.
• P4. Identify others colleagues’ emotions and their state of mind in handling a critical situation.
• P5. Help manage others’ stress and prevent a breakdown resulting from facing a stressful situation.
• P6. Provide means to motivate the staff and encourage the capacity to self-motivate.
• P7. Practice the use of the EI elements through internal audit procedure and mock recall procedures.
• P8. Provide feedback to staff and help them to embrace self-esteem and confidence.