SGS Societe Generale de Surveillance : Common Problems with Food Recalls, Potential Impacts and Recommended Solutions

Most food exporters, importers, manufacturers, packers, distributors, food service operators and retailers have recall programmes to remove from the marketplace products that have some form of hazard. Additionally, most firms test these programmes at least once a year, but this is a traceability test and not a demonstration of how effective the recall programme is from the perspective of companies, government and consumers.

The Canadian Food Inspection Agency (CFIA) has published the common problems, potential impacts and the recommended solutions for food recalls, to help the industry become more effective1.

There are seven areas in recall programmes that CFIA states are the most common:

• Notice of the recall
• Identification of the product(s)
• Product distribution list
• Informing the government agency
• Public notifications
• Controlling the product
• Verifying the effectiveness

Common problems for recall notifications include the hazard not being described clearly, the urgency or recall level not being stated, key facts hidden by promotional information and instructions on how to handle the recall programme are not provided or are vague.

These errors can result in a product not being recalled, its continued use by consumers and product not being removed in a timely manner, requiring additional notifications to be sent by the company recalling the product, or a government agency. Notifications must clearly state the hazard, for example, 'there is an undeclared peanut allergen in the product'. The recall notification must also state the urgency of the recall and if urgent, it must indicate this in the title in bold capitals.

Failure to identify all the products that are being recalled is another issue. Recall notifications must include all affected lots, sizes, brands and products affected. If this doesn't happen, products remain in the distribution chain or consumers' hands. This means hazardous products are consumed and additional notifications are required. Before a notification is issued, a mock recall needs to be performed to determine which product is involved, from the point of origin of the problem to its resolution. The list of products identified in the recall must be complete, detailed and only include the recalled materials. For consumer products, the Universal Product Code (UPC) should be included along with the product description. A picture of the product helps too.

Retailers, distributors and consumers frequently see recall notifications, so the word 'recall' is less important to them but 'urgent' still carries significant weight. Notifications should be brief and to the point and not include a sales pitch. Inform the people receiving the notification what to do with the product.

The CFIA requires firms to provide a product distribution list within 24 hours of the recall being classified. Typically, distribution lists are missing essential information, such as contact names, addresses and phone numbers. They are often unreadable and include companies not involved in the recall. Poor distribution lists cause products to remain in consumers' hands as well as delays in product removal and in determining the recall's effectiveness. Companies must develop systems to provide timely and accurate information.

Failure to inform, or promptly inform, the government agency of the recall is another problem. This can result in products being left in the distribution system or on the shelf and will create situations where some consumers will not be aware of the recall.

Most government agencies have experienced personnel to help facilitate the removal of a recalled product and instigate programmes to notify the public. Additional resources in a time of crisis helps and notifying the government agency demonstrates that the company is taking responsibility for their mistake and being proactive to protect the public.

Some firms try to remove recall products in secret. Others don't prepare their message to consumers ahead of time and others try to announce the recall in a manner that avoids publicity. Failure to notify consumers in a timely, public manner, causes recall products to remain in consumers' hands and in the distribution system. This negates the purpose of the recall, which is to protect people.

Speed and accuracy of removal of the recalled product is essential in mitigating the hazard to the public.

Problems occur during or after a recall where the product recalled is accidently shipped to customers or sold to consumers. Hence, the product may be placed on the shelves and consumed, thereby requiring another recall.

Unfortunately this happens frequently, as recall products are not clearly identified and not held in a secure manner. Recall products at all levels of the distribution chain and in manufacture must be clearly identified and kept separately and securely to prevent this from happening.

After a recall has taken place, most firms do not verify its effectiveness. This can result in product remaining on the shelf, or with consumers. Following up the effectiveness of a recall notification enables a firm to judge whether any elements of it were handled poorly. If so, non-conformances can be noted, with root cause analysis and corrective actions taken. Preventative actions must also be made to improve the programme in the event of a further recall.

Naturally, the best way to handle a recall is to structure a system to prevent it from happening in the first place but in the real world, mistakes happen and it is best to learn from the mistakes of others rather than making them ourselves.