Managing food safety withdrawals and recalls

All food businesses are responsible for the safety of the food they produce. Sterling Crew considers how effective food withdrawal/recall management enables food businesses and authorities to build capacity to safeguard food and enhance consumer confidence.

Introduction

Recent food scandals, scares and incidents have reiterated the importance of effective withdrawal/recall management systems. This is illustrated by events relating to foot and mouth disease, dioxin in Irish meat, Sudan 1 contamination (the UK’s largest recall), Salmonella and plastic in chocolate, melamine in milk along with the notorious horse meat fraud. There is a legal obligation to inform competent authorities immediately if food has been placed on the market which may be injurious to human health and for that food to be withdrawn or recalled. The ability to trace food and food ingredients through the supply network. has become critical for food businesses. Even the most admired and best managed food businesses and brands can still be involved in food safety withdrawal/recall incidents.

In 2015 there were 121 recalls in the United Kingdom (Table 1), which was more than double the number in the two previous years.

They involved a wide range of food commodities and organisations. Around half of the recalls (117) were related to allergens and roughly a quarter (57) were associated with microbiological and hygiene issues. Physical contamination, such as foreign bodies, accounted for 18% of the recalls. The rest related to other categories, such as unapproved chemicals. The recalls for the first three quarters of 2016 suggest numbers will be as high as in 2015.

Table 1. Number of UK recalls by type and year, 2013-2015

Withdrawal/recall planning

A ‘withdrawal’ is defined as a process by which a product is removed from the supply network, except for product that is already in the possession of consumers. A ‘recall’ is the process by which a product is removed from the supply network in which consumers are advised to take appropriate action, such as returning the food or destroying it. The human behavioural element of any withdrawal/recall programme cannot be underestimated. Withdrawal/recalls are by their very nature rare events that many technologists will never experience in their career. Individuals and organisations can be subject to optimistic bias ‘it will not happen to our organisation’ or an illusion of control ‘we know what we are doing’. There is also a threat of attitudinal ambivalence ‘there are more important urgent matters to deal with first’. Withdrawal/recall plans do not appear important until food operators are in the middle of a food safety emergency, then they become business critical.

A business crisis management system is a structured method that can be adopted in food related emergencies. If the food system is integrated into a total business approach, rather than stand alone, it has more chance of being sustainable, resourced and refreshed. A crisis is any event that has, or is perceived to have, the potential to significantly cause harm to an individual, damage the reputation of a business or its brand, or impact upon its financial position. A withdrawal/recall is certainly a crisis for any food business. However, handling a crisis well can help maintain customer and consumer trust and loyalty.

Organisations should not wait for a crisis to develop a crisis plan. Bad news travels fast with today’s social media platforms and businesses must be prepared to react quickly. They are equally accountable for what they do not do, especially if public health is involved. It is always better to initially overreact and follow a well thought out contingency plan. It is good practice to conduct a post withdrawal/recall audit to learn lessons and drive continuous improvement. An effective food withdrawal/recall plan (Table 2) consists of a set of documented procedures and support materials that are designed to facilitate the effective and efficient removal of food from the market and provide the correct and timely information to the supply network, consumers and the relevant authorities.

Third party accreditation can give additional confidence in a withdrawal/recall system. Crisis management is a key part of the Global Food Safety Initiative standard, the pre-eminent food safety industry programme. The leading certification standard in the UK is BRC Global Standard for Food Safety Issue 7: July 2015. In section 3.9, it requires that the food site shall be able to trace all raw material product lots (including packaging) from its suppliers through all stages of processing and dispatch to its customers and vice versa. Also, the site shall test the traceability system across the range of product groups including quantity checks and mass balance.

The International Organisation for Standardisation (ISO) has developed an accredited business continuity management systems standard, ISO 22301: 2012, which is designed to respond quickly and effectively to the threat of sudden disruption to business operations. It specifies the requirements to plan, establish. implement, operate, monitor, review, maintain and continually improve a documented management system to reduce the likelihood of occurrence and to respond and recover from disruptive incidents. A weak Food Safety Management System indicates inadequate risk assessment and mitigation and leads to poor crisis management.

In a crisis quick action needs to be taken to mitigate the threat. The incident management team needs to follow the prearranged plan, but must be prepared to manoeuvre according to the circumstances. Facts are assembled to make evidence based decisions. The team should maintain a contemporaneous log of events and decisions. The work needs to be allocated to individuals or teams and resourced, often using external centres of excellence. Protocols to Identify and contact internal and external stakeholders should be followed.

It is vital to carry out a ‘post mortem’ after the incident to understand the root cause of the failure and to ensure that lessons learnt are implemented. Failure can give an organisation a chance to improve its approach to managing and mitigating risks. The Chinese use two brush strokes to write the word 'crisis.’ One brush stroke stands for danger; the other for opportunity’. In a food crisis, be aware of the danger but also recognise the opportunity for continuous improvement.

Table 2. Elements of a withdrawal/recall plan

Organisations should not wait for a crisis to develop a crisis plan. Bad news travels fast with today’s social media platforms and businesses must be prepared to react quickly'

Food Traceability

Food safety incidents have highlighted the value of effective traceability systems. Traceability is a risk management tool, which facilitates food business operators or authorities to withdraw/recall food products that have been identified as unsafe. Food traceability is an important component of the modern food supply network and is recognised as an essential tool for ensuring food safety and quality. It is defined as ‘the ability to trace and follow a food, feed, food producing animal or substance intended to be or expected to be incorporated into a food or feed, through all stages of production, processing and distribution’ (Regulation 178/2002). Food and feed operators must be able to trace one step backwards from where the ingredients or food/feed were obtained and one step forwards to where the products were sold. However, it is good practice to ensure that the traceability process extends throughout the total network.

Food supply networks are becoming increasingly complex and globalised, making product traceability ever more challenging. The time taken to identify the problem and locate affected product batches will be critical in the decision making process. A retailer or authority may exercise a precautionary principle if the necessary information is not forthcoming, especially if the potential risk to public health is high. General Food Law requires that food safety records must be available on demand.

Food traceability management systems are resource intensive which can place a disproportionate burden on small companies. There is also a danger that they can become overly bureaucratic and costly to maintain. But the costs of having an effective system are far outweighed by the potential costs of not having one, especially in terms of the risk to public health.

Food traceability systems have been greatly enhanced and simplified by modern technological developments, including managing traceability data through faster electronic data exchange, which facilitates and integrates more effective supply network information sharing. The Rapid Alert System for Food and Feed (RASFF) network is a European warning system that has been in place since 1978. If a food or feed safety risk is identified, it helps to support rapid electronic distribution of information and corrective action. Product identification has been improved using Radio-frequency identification (RFID), barcoding, biocoding and genetic analysis. Consumers place a value on traceability not only because it can enhance food safety but also it is an assurance of a product’s provenance and can enable informed food choice.

Table 3 Developing a food traceability system

Legal requirements

If a potential food hazard has been identified, the resultant food safety risk must be assessed. The food safety risk is a function of the probability of an adverse health effect and its severity, in other words, what is the potential harm and how likely is it to occur? This is a scientific process consisting of four steps: hazard identification, hazard characterisation, exposure assessment and risk characterisation. A key part of the assessment could involve engaging with reputable third party centres of excellence, such as the food research associations Campden BRI and Leatherhead, universities, trade bodies, suitably accredited pubic analysists and laboratories. However, if the food is in control of the operator there is no requirement to notify the authorities.

There are a number of regulations governing food withdrawals/recalls and it is important that individual food businesses are aware that it is their responsibility to ensure compliance to the legislation.

Under Regulation (EC) 882/2004, the Food Standards Agency has the power to enforce a recall if necessary. It is the single point of contact for notifying a recall and communicates the recall information. The Agency produced an official guidance document in 2007, ‘Guidance Notes for Food Business Operators on Food Safety, Traceability, Product Withdrawal and Recall’, which provides informal, non-statutory advice to food businesses on compliance with the relevant regulations. However, this guidance lacks detail about good practice in managing a recall and testing and evaluating recall plans. There is also no risk ranking relating to food safety. The Guidance Notes Notes only provide advice; the courts alone can decide if an offence has been committed.

Regulation (EC) 178/2002 on the general principles and requirements of food law aims to protect human health and consumer interest in relation to food. Article 19 of this regulation provides for the withdrawal from the market of foods‘not in compliance with the food safety requirements’and requires food businesses to inform the competent authorities, and if necessary the consumer, of the reason for its withdrawal.

Conclusions

Improvement in food crisis management and systems enables food business and authorities to build capacity to safeguard food and enhance consumer confidence. Food businesses must be prepared to challenge their withdrawal/recall management systems and ask very difficult questions to ensure procedures are robust. Food operators should not only attempt to comply with legislation but seek to follow best practice.

Sterling Crew FIFST, FCIEH, FRSPH, is Head of Technical at Europe Snacks - Kolak Snack Foods Ltd, Vice President of the Institute of Food Science and Technology and Chair of the IFST Food Safety Group.

Email:Sterling@Kolak.co.ukwww.ifst.org