Make Sure Food Safety Includes Critical Recall Training

Your food processing operations need to have the same kind of preparedness for food recalls as it would have for a natural disaster. Be sure to keep up with training.

1222 Food Safety

Recent natural disasters, such as Hurricane Ian in late September, have shown the continued importance of planning and preparedness. Some businesses are required to have a hurricane emergency action plan to meet requirements under Federal Emergency Management Agency (FEMA) regulations, and training is an essential component of any adversity recovery plan.

The same kind of preparedness is prudent when it comes to food recalls. For foods regulated by the U.S. Food and Drug Administration (FDA), updated regulations can be found in the Food Safety Modernization Act (FSMA) regulations, which states that facilities must have a written recall plan that includes procedures and steps to do the following: notify their consignees about the recall, notify the public about the hazard, notify the FDA, conduct checks to verify the recall effectiveness (retrieval of product), and appropriately dispose of the recalled food. Triggering and conducting a recall is still a voluntary act that is up to the company. However, the FDA now has statutory authority (under the FD&C Act) to mandate a company recall if the company refuses to do so and the FDA deems it necessary to protect public health by preventing an adulterated or misbranded product from remaining in the marketplace.


Read article   Read how food and beverage recalls spiked in 2022 in our latest Global 250 report.

Many of the misbranded food recalls consumer packaged goods (CPG) companies deal with (typically greater than 40%) are due to the presence of undeclared allergens on the label. The estimated cost to the company of a recall could be in the millions of dollars, so it is easy to see why CPGs need to get serious about recalls and recall training efforts. Planning and preparedness are key to minimizing the impact of a food recall, and it is the task of the food safety team to create and manage the company’s food safety programs to prevent, plan, and prepare for such an event as a food recall.

When a problem occurs, a company should internally decide if and when a recall is necessary. In some situations, the company might consider that an internal action is warranted when there is no or very limited public exposure to the problem. The decision needs to be made about whether it can be managed through an internal correction, stock recovery, or market withdrawal of product. However, a company must consider a recall when its product or ingredient is adulterated or misbranded, requiring the company’s removal or correction of a marketed product that the FDA considers to be in violation of the laws it administers and is a threat to public safety. Also, the company must take several steps while handling a recall: notify the FDA when a recall is eminent by using the FDA’s Reportable Food Registry portal, notify the company’s supply chain with details, prepare and notify the public via press release(s), conduct a product recovery, correct the problem, and draw an end to the recall.

Managing a recall takes preparation, planning, and practice. Some companies might never experience a recall situation, but every CPG company must nonetheless have plans in place and be familiar with the basic steps that must be taken to quickly and efficiently implement a product recall and product retrieval. If the decision to recall is not readily apparent, it might be wise to engage experts, risk consultants, and legal professionals as needed.


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