8. Traceability, Recall & COVID-19

Recorded May 4, 2020

8. Traceability, Recall & COVID-19

36 Minute Webinar

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Webinar Notes

During the COVID-19 crisis, the risk of mistakes due to increased production and decreased staffing make a strong traceability and recall plan essential. In doing so, you can help keep consumers safe and strengthen your customer relationships.

Most Likely Recalls

According to the FDA’s most recent (2016) Reportable Foods Registry (p. 10), undeclared allergens, Salmonella and Listeria are the most common reasons for Class 1 recalls, accounting for 91 percent of all recalls. Class 1 means that there is an actual or potential for “death or severe illness.” In these cases, the acronym used by the FDA is SAHCODHA, which means Severe Adverse Health Consequence or Death in Humans or Animals.

The most likely recalls by product type include:

  • Bakery/Snack food – Undeclared allergens
  • Mild ripened cheese – Listeria monocytogenes
  • Nut products – Mycotoxin and Salmonella
  • Fresh fruits & vegetables – Pathogenic E. coli
  • Dairy products – Variety of pathogens
  • Meat, Poultry & Seafood – Variety of pathogens
  • Egg products – Pathogens, pesticide residue

Most objective persons would conclude each of these are preventable if proper controls are in place to prevent cross contamination with pathogenic bacteria or undeclared allergens in raw materials or finished product. Thus, the goal for current regulations is to reduce “preventable” recalls by having documented controls in place.

As recalls are increasing at approximately 10 percent per year, it is safe to say that most companies could have been more thorough in identifying preventive controls that could have reduced the likelihood of recalls.

When Prevention Doesn’t Occur

In the U.S., if you believe your food product is unsafe, you must report this information to the FDA through an electronic portal within 24 hours after you have decided the food is or could be unsafe and that food is out of your control, i.e. the food has entered commence and is not directly in your control. Other countries have similar requirements and definitions for what constitutes a reporting to the regulators and your responsibility to assist regulators in removing that product from the market.

Notably, all countries have requirements for the removal of unsafe food from the marketplace and to inform consumers and regulatory agencies that the food is unsafe.  The amount of regulatory interaction and the effectiveness of performing recalls will vary depending on the resources and sophistication of their regulatory agencies. The importance is that you must read the regulatory requirements and guidance documents that explain the performance expectations when doing a recall.

Further, recalls that involve exports to other countries can be very complex in that you must be knowledgeable about multiple regulations. You must comply with the specific regulations of the country to which you are exporting.

Develop Your Recall Plan

Most food manufacturers are required to have a recall plan readily available. Even if this were not a regulatory requirement, it is a necessity for your food safety plan. The recall plan should include management’s strategy to take quick and effective action when experiencing a recall. If needed, this plan will be an invaluable guide to walk your company through the steps to take during the recall. Our Food Safety Professionals can guide you through the development of an effective recall plan.

Double-Check Your Traceability Plan

Our AIB International technical experts can provide a comprehensive review of your site’s written traceability program with our Traceability Performance Assessment. This includes a timed traceability response exercise that evaluates employee practices, understanding of responsibilities and documentation tracking.

Execute Your Recall Plan

Take our Traceability & Recall Online course to learn how. Thousands of products are recalled each year due the growing complexity of the supply chain, better detection of food safety issues, and more efficient mandated reporting by manufacturers. Be prepared and confident, so your team can lead an appropriate and swift response during a recall.

Perform a Mock Recall  

Assemble Your Team – The success of a recall plan is largely dependent upon the knowledge and skills of those executing the plan. For this reason, the selection and training of the recall team members is a critical activity in the development of the plan. It may be best to first identify the activities that must be covered during a recall before identifying team members. The activity may dictate who would be best to hold the responsibility for it.

Throughout the process, you will evaluate your ability to execute, keeping track of the time it takes you to perform the collection and communication of information at each step.

Following your execution of the mock recall, you can then conduct a gap analysis to determine where improvements can be made.

Should you have questions or need additional information, please email us at info@aibinternational.com.

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