by Lisa Tomassen
Trust in our food supply has been put at risk. Consumers want to know more about the food they are eating and serving to their families. The rise in food recalls over the past few years has politicized this public health concern and questioned the effectiveness of many food companies’ processes. In this article, I will talk about what a food recall is, why it is important, and what companies are failing to do when safeguarding their consumers from problems with their products.
A food recall is action taken to remove unsafe food from distribution, sale, and consumption. Food businesses must be able to quickly remove food from the marketplace to protect public health and safety. Recalls are instigated as a product is classified as unsafe for human consumption. The three primary objectives of a food recall according to Food Standards Australia New Zealand (FSANZ) are to:
- Stop the distribution and sale of the product as soon as possible
- Inform the government, the food businesses that have received the recalled food, and the public (consumer level recalls only) of the problem
- Effectively and efficiently remove unsafe product from the marketplace.
Recalls are classified according to the problem with the food. These problems can include:
- Microbial—contamination with pathogenic microorganisms such as bacteria, viruses, or parasites.
- Labelling—non-compliant labelling, incorrect food ingredients on the ingredient list, incorrect date markings, or other food labelling errors.
- Foreign matter—contamination by material such as glass, metal, or plastic objects.
- Chemical/other contaminants—contamination by substances such as cleaning products, pesticides, machine oil etc.
- Undeclared allergen—due to incorrect labelling, incorrect packaging, or contamination of the product by an allergen.
- Biotoxin—contamination by biological toxins such as histamine in fish and paralytic shellfish toxin in oysters.
- Other—for example, packaging faults or unsafe levels of additives.
Food recalls can be at the trade or consumer level.
- A consumer recall is the most extensive type. It involves recovering the food from all points in the production and distribution chain, including consumers.
- A trade recall recovers food that has not been sold directly to consumers. It involves recovering the product from distribution centres and wholesalers; and may also include hospitals, restaurants, or other catering establishments.
A food withdrawal is different from a food recall. The process involves removing food from the supply chain where there is no public health or safety issue (e.g., if the product is underweight or has a quality defect).
Sharing an experience
I was employed by a medium-sized food manufacturing business which packed cereals, nuts, and snack foods. A call was put through from our consumer call centre—a customer was claiming to have found peanuts in our newly launched Nut Mix which had a “peanut free” claim on the front of the packaging. The year was 2002. I know it was a number of years ago, but it still lives fresh in my mind.
It had been a mandatory requirement since 1994 for food businesses to have a food recall plan, however the business hadn’t managed to get around to localizing a plan. We floundered through the recall. Each step of the process had to be researched. We got through it, but the execution of the recall was overly stressful for all involved and did not demonstrate a business that was under control.
What did the company learn?
- A company must have a fully-functional traceability system that enables forward and backward traceability in a timely manner.
- A company must have a recall team that is familiar with the requirements of their recall plan.
- The team must practise for a potential food safety incident that could result in a recall. A mock recall exercise is a valuable tool—provided it is executed by the whole recall team and involves executing all steps of the plan, completing templates, checking internal and external contact details, referenced websites etc.
- The quality control team is not the recall team. The recall team must comprise representatives of multiple departments of the business: senior management, operations, distribution, quality, sales and marketing etc—basically the key staff who can contribute to completing the recall in an efficient and effective manner.
- Retention samples are important. As we kept samples of each batch of product produced, we were able to confirm quite quickly that the complaint was not an isolated issue.
Overview of recalls in Australia
Between January and March 2017, there were 15 recalls reported to FSANZ—11 were products of Australian origin. The following sample of 2017 recalls demonstrates the broad range of products and issues involved in recalls:
(Disclosure: The following list of recalls are publicly available; http://www.foodstandards.gov.au/industry/foodrecalls/recalls/Pages/default.aspx)
- The Pork Pie Shop Pies—potential Salmonella contamination
- Cottage Cheese Farm Ricotta—microbial (E.coli) contamination
- Yummy Mini Tub Yoghurt Sultanas—undeclared allergen (peanuts)
- Birds Eye Golden Crunch Hash Browns—foreign matter (small blue plastic pieces)
- The Cider Lab Ciders—presence of an undeclared allergen (sulphites)
- Organix Finger Foods Baby Biscuits—potential choking hazard
- Jinyuanbao Chinese Wonton—presence of an undeclared allergen (wheat).
Recalls can have significant impacts on a company’s brand and profits. A recall was instigated in February 2015 on Patties Foods’ (Nanna’s and Creative Gourmet brands) frozen berries range due to potential Hepatitis A contamination. It was estimated to have cost Patties Foods $14 million (drop in net profit), however the ongoing impact on the brand must also be considered as a cost.
Why is the incidence of recalls in the food industry so high?
- Are manufacturers challenging the shelf life of products beyond the capability of the product?
- Are the rigours around product design and development insufficient?
- Are manufacturers failing to conduct adequate food safety risk assessments prior to launching new products?
- Does the thin profit margin (that the food industry normally operates within) prevent companies implementing a sufficiently rigorous food safety program?
- Are changes in eating habits and the increased level of product testing the reason for the growing number of recalls?
- Are the hygiene and structural standards of manufacturing facilities capable of preventing product contamination?
- Are production quality control checks failing?
Back to food safety basics
Food manufacturers need to go back to the basics of food safety. Companies need to be certain about the food safety and integrity of the ingredients they use. Manufacturers need to be honest with themselves and truly understand the risks of the ingredients, processes, and finished products that they are handling. Effective internal auditing, rigour in corrective action systems including root cause analysis, allergen management, and controls relating to packing product into the correct packaging format are vital processes.
As an organization, PwC is increasing its footprint into the food industry. PwC has more than one and half centuries’ experience in helping companies grow, reduce supply chain risks, and improve the processes and systems that build trust and add business value. It is for these reasons that we’re confident we have the range of capabilities you need to help build trust in your food.
We can assist with an independent review of a food safety program. Our Auditor Training & Certification team can help meet training needs via food safety, quality, environment, and OHS courses, as well as short courses specific to how to conduct an effective recall.
In the coming months, PwC will become an accredited certification body offering certification to various industries across multiple standards—helping our clients gain access to even greater markets and build confidence in their business.
About the author
Lisa Tomassen has over 20 years’ experience in helping bring about effective food safety management in both larger enterprise and small business. Tomassen’s particular focus is on integrating food safety and quality management system audits against multiple standards. In 2014, Tomassen was awarded an accolade by Advancing Food Safety—an independent food industry body—in recognition of her achievements as a food safety auditor. Tomassen conducts food safety and lead auditor training on behalf of PwC Australia; PwC’s Auditor Training & Certification.
For more information about how PwC’s Auditor Training & Certification can help your system’s needs, visit auditortraining.pwc.com.au.