Does Your Company Have a Recall Readiness Plan?

Has your food safety team identified your company’s biggest food safety vulnerabilities based on the nature of its business? Perhaps the most important component of any crisis plan is to initially conduct a vulnerabilities assessment with top management to determine the incidents that could most impact your company’s reputation and financial well-being. It should not be surprising that product recall tops the list among most companies as a high risk issue.

Forming a Crisis Team and a Strategy Plan

Is your Food Safety and Communications staff working together as a Crisis Team to be prepared for any crisis situation, including a recall, at a moment’s notice? Many companies engage professional assistance from an experienced public relations team with food safety issues which includes working with your Crisis Team in implementing a communications strategy during a crisis.

In the case of a recall, a crisis plan usually includes written descriptions of possible pathogens as defined by FDA and USDA that could occur if left undetected and eventually threaten human health. This year one in six Americans will become ill from food poisoning totaling 48 million incidents, resulting in 3,000 deaths. According to FDA, undeclared allergens and Listeria monocytogenes contamination are currently the leading causes of product recalls. Having definitions of these culprits and others available eventually frames a specific issue and provides basic information for the Crisis Team to use in a crisis.

Additionally, the Crisis Team also identifies how the FDA classifies various levels of recalls and their strategies that could ultimately drive how the recall will be handled. FoodSafety.gov provides food safety and food recall information from both FDA and the U.S. Department of Agriculture (USDA). The following are the levels of recall situations as defined by FDA:

Class I recall

A situation in which there is a reasonable probability that the use of or exposure to a violated product will cause serious adverse health consequences or death.

Class II recall

A situation in which use of or exposure to a violated product may cause temporary or medically reversible adverse health consequences or where the probability of serious adverse health consequences is remote.

Class III recall

A situation in which use of or exposure to a violated product is not likely to cause adverse health consequences.

Market withdrawal

Occurs when a product has a minor violation that would not be subject to FDA legal action. The firm removes the product from the market or corrects the violation. For example, a product removed from the market due to tampering, without evidence of manufacturing or distribution problems, would be a market withdrawal.

Establishing a Safe Food Culture is Critical

Once the Crisis Team includes the regulatory process for a recall in its plan, the Communications Team can formulate a communications crisis strategy for use in any situation, including a recall. Most importantly, after the Crisis Team has completed its crisis plan, it must be communicated to the management team for final comments before it is unveiled to all employees as an ongoing part of creating a safe food culture that everyone in the company embraces.

At the core of the recently released FSMA regulations is a mandate to not only take every preventative step possible to defend against a crisis situation, but to also engage the CEO in an ongoing dialogue with all employees about their important role in assuring a safe food supply throughout the operation. Just as critical in creating a safe food culture is having proof of an ongoing continuous improvement operational plan with preventative controls that includes updating the crisis plan and sharing it annually with all employees.

Determining Communications Strategy

In the case of an actual recall, it is most likely that a company will become aware of an emerging issue before outside parties, including the media, are engaged in it. This allows the Crisis Team to gather information, assess the situation and make strategic decisions about communication approaches to various audiences. After gathering and reviewing key information quickly, the team then evaluates and discusses key issues to assist in the development of a communications game plan. At this point, the team should identify the various constituencies that may be impacted by the crisis and anticipate a variety of messaging needed to address their concerns. This is when the team will reference its Crisis Plan for the FDA definitions of the pathogen, etc., involved in the crisis.

Assessing the status of the emerging issue is also key. This is a matter of whether the issue is contained to a single consumer inquiry or a few consumer inquiries; whether the investigation is just beginning; or if there is a likelihood that the involved parties, possibly including regulatory bodies, may resolve the matter without a need to alarm the public. On the other hand, it may be clear that it will emerge as a very public issue. This is where the team can reference the various levels of recall and possible strategies and outcomes as defined by FDA recall protocols.

The media will be looking for comments and controversy when a crisis emerges. Ideally, the Crisis Plan includes media training in a variety of situations with designated spokes people, including the CEO and the leader of the Food Safety Team. The company’s focus should be on the facts as it knows them and solving the problem at hand. Beyond that, its role is to reassure the public of its past, current and ongoing commitment to delivering high quality and safe products while also seeking to protect the well-earned reputation of the brand, employees, producers and processors and/or others as appropriate.

Where another industry or government entity is planning to issue a media statement or conduct an interview on the issue, it’s important that the company coordinates with these organizations to ensure the information is accurate and the messages being delivered to the public are consistent. For example, cooperation and communication with government agencies – particularly the FDA – is critical in a recall environment. Becoming familiar with the state and federal level authorities and working with them on an ongoing basis will help everyone feel more familiar in a crisis situation where working together is critical.

Other considerations include whether a third-party expert can comment on the company’s food safety commitment and track record or whether to issue a statement or provide a company spokesperson. Then, the crisis team should reach consensus on the tone and tenor of the response and whether a reactive or proactive approach best fits the current situation. Again, being familiar with experts in the industry and building common knowledge and trust ahead of time will reduce the stress of a fast moving situation. In addition, these experts should be aware that you have identified them as a possible expert spokesperson in a crisis situation.

Regardless, the goal should always be to respond accurately, compassionately and consistently. Finally, the communications strategy should deliver a consistent message to all key audiences identified by the team, including employees and suppliers. Key messaging points should already have been identified and approved by top management in the Crisis Plan when the company’s highest risk vulnerabilities were first identified. In an ideal safe food culture that has been nurtured by the CEO throughout the organization on an ongoing basis, a crisis situation presents an opportunity to showcase your company’s dedication and perseverance at producing the safest products in the world! To learn more from the experts, attend the Safe Food California 2017 conference at the Hyatt Regency in Monterey on June 6-8.