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A reporter contacts your company to ask for a comment on a hazard alert for one of your products. You receive notice of a lawsuit from a legal firm. A consumer reports an illness caused by one of your products. When unexpected situations arise, suddenly your company’s reputation – even its survival – may be at risk.
The risks and impacts associated with a recall are high. It can happen to virtually any manufacturer – regardless of how much attention is devoted to the product. Quality assurance may reduce recall risks, but it can’t eliminate them.
This is especially true in the food and beverage processing sector, which is particularly vulnerable to recalls. With the rapid growth of Canada’s food processing industry, companies are at the front lines when it comes to ensuring the safety of their production. In fact, the federal government announced in December that it is working on new food safety legislation to improve consumer protection.
Make risk management a top priority and addressing a potential recall should be part of the strategy. It’s essential to reassure customers, regulators, retailers, distributors – even bankers and insurers – that doing business with your company is a safe undertaking.
A documented and practiced action plan will help protect your company and your customers while limiting your liability if the worst happens. All aspects of the crisis must be managed. Your company’s recall plan will be specific to your organization’s needs, but it should include the following basic components:
Identify the individuals and departments (for example, representatives from management, quality assurance, technical, legal, regulatory and communication) who would be involved in a recall and outline their responsibilities.
A documented process identifies unsafe products and corrects problems. The process should encompass information gathering, investigation and taking appropriate action.
Food and beverage processors need a food safety plan to address stringent government policies and regulations. These plans relate to safe food handling and manufacturing processes, and ways to keep food secure throughout the supply chain.
It quickly tracks products from suppliers through processing and packaging to finished product and distribution. This is especially important for food and beverage processors that must limit the scope of a recall and facilitate the rapid removal of problem products from distribution.
They’ll help you quickly determine the amount of product within or beyond the control of your organization by generating accurate distribution records with lot codes of each product produced.
You need to identify and document the specific steps your company will take to identify problems with products, possible causes and solutions. These steps might include for example, convening the recall team, conducting a risk assessment, stopping product production or delivery, notifying appropriate regulatory bodies, and establishing internal and external communications.
Conduct tests through simulation exercises and update the plan on a regular basis to ensure your recall plan works when needed and the recall team has been properly trained.
Once you have documented and tested your recall plan, communicate it to employees as well as your supply chain partners. Their understanding will help to ensure that any recall is conducted in an efficient, coordinated manner.
Don’t procrastinate when developing a plan. If a crisis arises there won’t be enough time to devise an effective solution. After all, when customers think about your brand, you want them to regard your products as healthy and trustworthy – not to recall that your products were recalled.
Glenn Fraser, CA, MBA, is the Leader of the Greater Toronto Region Food & Ag Processing team of MNP LLP and Cliff Trollope, CBCP, CRM, CAS, is MNP’s Business Resilience Practice Leader.
Published in the January/February 2012 issue of Plant magazine.
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