Sep 26, 2016

Plan for food safety recalls before they happen

Preparing for a food safety recall can be daunting, but a little planning can go a long way, according to Amy Philpott, a senior director at Watson Green, a communications firm based in Washington, D.C.

According to a presentation Philpott gave during the 2016 Mid-Atlantic Fruit & Vegetable Convention, a basic recall plan identifies a farm’s internal resources, roles and responsibilities, and lists experts who can be called upon to help.

“If the farm has planned and practiced for a recall, it will be difficult,” she said. “If the farm has not planned and not practiced, it will be a nightmare.”

Philpott gave a brief list of what to do to prepare for a recall:

• Identify your team. A team of between five and 10 people can work well in most cases. If the farm is extremely small, spouses and adult family members may need to help temporarily.
• Assign roles and responsibilities. You need decision makers and people who can communicate with customers, employees, government officials, insurance companies and lawyers.
• Know who to call. It may be necessary to hire outside professionals. Companies commonly need help with crisis communications, regulatory compliance and health hazard analysis.

The plan

According to Philpott, a recall plan should consist of five rough steps: gathering information, assessing the situation, making the decision, carrying out the recall and terminating the recall.

Plans often incorrectly begin with executing the recall, when the most important work is often done in advance of that decision. Gathering information should be the first order of business. In order to decide whether or not to issue a recall, the team has to assess what is known, what matters and what doesn’t matter. The seriousness of the situation determines how quickly the farm has to act, she said.

While facts are being gathered, the farmer must decide what, if any, immediate administrative actions should be taken. These actions may include halting harvest or temporarily closing the packing facility, she said.

Keep in mind that the farm and its consumers might view risk differently. News reporters and customers will want to know how the farm reacted when it first learned there was a possible problem, Philpott said.

Executing the recall

A properly prepared farm will have already drafted many of the documents that will be needed in the first 24 hours of a crisis. If a farm waits until after the recall decision has been made to turn its attention to communication, it will be too late to stay ahead of the message, according to Philpott.

She recommended following these steps when executing a recall.

• Notify the FDA recall coordinator.
• Notify the insurance company.
• Finalize the press release and let FDA review. FDA does not have to “approve” the release, but might suggest changes.
• Finalize the recall notification letter to customers who received the recalled product. This will include instructions on what to tell consumers.
• Contact customers who received the recalled product.
• Train anyone speaking for the farm. Once the release and messages have been finalized, ensure the messengers know how to deliver them, can answer basic questions and know how to handle the questions they cannot answer.
• Finalize website copy and post to website with recalled product photos.
• Issue the press release. There are specific wire services and email addresses FDA requests be used to distribute the release.

Terminating the recall

Philpott gave this advice for wrapping up a recall.

The farm will likely want to communicate with several groups for some time after the recall is out of the news cycle.

Employees should return to their regular responsibilities as soon as possible. It is critical to maintain a balance between keeping employees informed and keeping them motivated and focused on daily work.

A postmortem discussion is an excellent idea. Understand what went right and what could have been done better, and update the farm’s recall plan based on what was learned.

If the farm is involved in lawsuits, communication messages must be consistent with and support the legal strategy. The farm should prepare to handle periodic media coverage about the lawsuits.

The farm will spend time working with customers or buyers to reestablish trust.

The farm must submit periodic status reports to its FDA recall coordinator. Generally speaking, the reporting interval will be between two and four weeks, depending on the relative urgency.

Even if officials do not link the recall to a public health impact, there will be people who claim illness and injury, and those claims should be taken seriously and handled in a professional manner. The time needed to close out liability and insurance claims will depend on the number and types of claims.

— Matt Milkovich, managing editor