Take a Proactive Approach

Today’s food processing facilities have put stringent measures into place aimed at preventing food safety issues. Despite those measures, recalls are still a fact of life. For the third quarter of 2013 alone, in fact, the ExpertRECALL Index from Indianapolis-based Stericycle ExpertRECALL reported 252 food-related recalls.

Whether it is voluntary, performed at FDA’s request or initiated under FDA orders, a food recall associated with a retailer’s own brand can be very damaging in terms of consumers’ trust in the brand — and in the banner. Every retailer that has a private brand program, therefore, should work closely with its suppliers on recall avoidance — and also put into place a plan aimed at minimizing both risk and reputation in the event a recall is necessary.

Strive for prevention

Many recalls these days are related to unreported food allergens, notes Gina R. Nicholson, RS, global client director of Ann Arbor, Mich.-based NSF International Retail Food Services. She adds that the number of U.S. children with food allergies climbed by 50 percent between 1997 and 2013, citing a 2013 report from the Centers for Disease Control and Prevention.

“Food allergies are a serious issue, and it is the responsibility of manufacturers to pay close attention to details as it relates to product labeling on packaging so that the consumer is properly informed,” she says. “This helps protect the consumers’ health and safety and the retailers’ reputation.”

Julie Wankowski, director of technical services for Chicago-based Silliker, also advises retailers to pay close attention to the “nuts and bolts” of food safety: management of allergen control and cross-contamination programs.

“There is no question that product recalls in our 24/7 media climate can have a detrimental impact on food brands,” she says. “We have found, however, that retailers are strongly committed to making necessary improvements in their food safety management programs. This is evident in the number of companies that are embracing the Global Food Safety Initiative (GFSI).”

Heena Patel, technical director, supply chain food safety audit services for Emeryville, Calif.-based SCS Global Services, acknowledges that the common expectation for suppliers to become GFSI audited has put a larger spotlight on food safety. Most certification bodies have upgraded good manufacturing practices programs to a higher level as a result. But label inspection programs also are critical to ensure the correct label is used on product in consideration of product changeovers and production starts. Moreover, retailers also need to be hands-on when it comes to their store brand suppliers’ operations.

“Retailers also need to have technical personnel on their team to conduct supplier audits — announced or unannounced audits — and choose the right co-packers,” she says. “Risk analysis must be conducted on products to assign them a high, medium or low risk. … Expectations on food safety, quality and legality requirements of suppliers must be based on the risk assessment. The product specifications must be approved by retailers.”

Wankowski notes that most retailers already have put into place “robust supply chain management programs” that aim to help prevent product recalls. But they still need to monitor such programs rigorously.

“Typically retailers monitor product and program attributes such as key measures for both domestic and imported raw materials to ensure their standards are being met,” she says. “This oversight is integral to the success of supply chain management programs.”

To be effective on the food safety watch, retailers also need to adopt a food safety culture, Nicholson adds. And senior management’s buy-in is crucial to their being able to do so successfully.

“Retailers should look for suppliers that share the same passion for developing and sustaining a food safety culture,” she says. “Food safety expectations need to be communicated and clear in order to be followed. They need to work together to ensure that proper controls, procedures and behaviors support safe food for their customers.”

Michelle Elizondo, marketing manager for West Liberty, Iowa-based West Liberty Foods LLC, echoes the importance of working with suppliers that place high value on food safety.

“Only purchase from reputable suppliers,” she advises. “Don’t think the cheapest or the largest has everything together. Third-party audits are part of the picture, but know the key people in the company and develop a relationship with them.”

And when the retailer is also the manufacturer of store brand products, it must follow Food Safety Modernization Act standards, but also should work to meet a GFSI scheme certification at each of its processing plants, Nicholson says.

“When working with a certification body, the retailer should insist on unannounced audits to receive an accurate picture of how the facility performs at any given day of the year and not just when they have a scheduled certification audit,” she says. “Additionally, retailers should have a regular unannounced internal audit program that incorporates proper coaching and training during the audit process and a follow-up corrective action plan.”

Be prepared

No matter how diligent a retailer is in its oversight of store brand suppliers, recalls are still bound to occur. For that reason, every retailer should have a solid recall plan in place that covers both its own-brand food products and other food products sold in its stores.

“Despite documented gains in food safety, regrettably, there is no such thing as zero risk in food production,” Wankowski stresses. “Companies must have a well-documented and validated crisis management recall plan in place to minimize the impact of product recalls.”

At the heart of such a plan should be effective consumer communication, she adds, via both traditional communication channels that include television and print, as well as social media outlets.

“To ensure the delivery of a seamless and cohesive message, the responsibilities of key company players must be clearly defined in all recall communication plans,” Wankowski says. “Being able to promptly and effectively respond to a recall allows companies to exercise some control over it and, consequently, limit its impact.”

Retailers need to train recall team members in advance, Patel adds, and assign and train back-ups for critical team members as well. Moreover, they need to set up contact lists comprising all stakeholders in automated notification systems. Retailers also might want to consider using an incident management system, she says, which allow recall team members at a variety of geographical locations to exchange real-time information.

“Communicate internally and externally,” Patel advises. “Assign ownership for the various potential crises within your organization to the appropriate communications staff. Arrange for notification of key personnel with whom you’ll have to interface during the crisis, particularly including general counsel, security, human resources and executive management. Be sure to have home phone numbers, vacation contact information and executive assistant contact info.”

The foundation of a good recall plan, Nicholson says, requires two-way communication among stakeholders that include the customers, the store(s), the distribution center, the manufacturing facility and the farm.

“Customer loyalty cards, receipt tape messaging, social media and broadcast media are all important tools to communicate recalls to customers,” she says. “Retailers must not only have quick and efficient communication methods, but also a solid documentation procedure recording that all product recalled was removed from shelves and storerooms and disposed of properly and in a timely manner.”

Retailers also should have their operations field team perform “spontaneous unannounced” checks in stores, Nicholson adds, to verify recall removal and disposal efforts.

Finally, retailers need to test the recall plan to ensure it will work. Mock recalls, therefore, are crucial, Elizondo says.

“Every situation is a bit different, so media training prior to the event is also essential,” she adds.