By Nuno F. Soares
Food scandals can be frightening due to the harm and fear that they cause, but unfortunately, they happen from time to time. For example, on March 17th 2017, the Brazilian federal police accused some of the country’s biggest meat producers of corrupting health inspectors to turn a blind eye to bad practices, including re-packaging beef past its sell-by date, making turkey ham out of soybeans, and overusing potentially damaging additives. The police operation impacted Brazil’s meat exports, worth $13 billion a year and damaged its two big global meat producers, JBS and BRF, who lost almost $2 billion in one day.
In Europe, a food scandal in July 2017 saw millions of eggs pulled from supermarket shelves because they were contaminated with fipronil—an insecticide harmful to human health. This is a common ingredient in veterinary products to combat fleas, lice, and ticks. However, it can cause anomalies in the kidneys and thyroid if consumed by humans. The use of this product is not allowed around animals destined for consumption. During this crisis, 180 farms were placed in lock down until they were fully tested for the substance, which caused serious consequences for the Dutch livestock production sector and its economy in general.
Product recalls happen regularly, and this it is an important issue because they can prevent serious damage to the consumer’s health. According to FAO, product recall is “the action to remove food from the market at any stage of the food chain, including that possessed by consumers”. However, there are some countries who use the term “market withdrawal” in relation to food recall. According to the FDA, a market withdrawal occurs when “a product has a minor violation that would not be subject to FDA legal action”. Basically, 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.” Food safety standards like BRC, IFS, and FSSC 22000 use the term withdrawals to describe a product recall that has not yet reach the final consumer.
Problems resulting in a recall may be identified by the suppliers, manufacturers, consumers, or health authorities, and the firm must assume responsibility to determine the nature and extent of the problem and take appropriate actions. Therefore, the companies should have a written recall plan that has been carefully developed and tested to ensure efficiency. The stages of the food recall process could be:
- Identifying and assessing the problem
At the beginning of the recall, the company must notify the person responsible for this procedure (internal or external) that there is a potential food safety issue. If a recall management team exists, these members should be informed and know their responsibilities during the recall.
The potential food safety issue must be evaluated, including:
- Identifying the hazard associated with the food—if it is microbiological, physical, or chemical;
- Determining if the hazard poses a food safety risk;
III. Determining what action is needed to manage the food safety risk;
- Looking for expert advice from the home state enforcement agency, if needed; and
- Evaluating if it is necessary to stop production and/or place product on hold.
The extension of the recall to other products should also be assessed.
- Identifying affected product(s)
In the next step, the organization must identify where the affected products are and confirm that contact information is available.
- Notifying health authorities, business-stakeholders, and consumers of a recall
The health authorities must be contacted as soon as a recall is needed or may be needed. All customers—including distributors, wholesalers, food service, retailers, and exporters—should also be notified. It is also important to keep records of these notifications to ensure that all businesses that have been supplied with the affected product have been informed of the recall.
If it is necessary to notify consumers, this must be done via a press release in consonance with health authorities to spread in one or more communication channels, such as radio announcements, website notifications, or direct notifications email or SMS.
- Food retrieval and disposal
It is also important to give customers (including retailers, distributors, wholesalers, exporters/other as applicable) recommendations of what to do with the product. Recommendations can include:
- Separating the product from other food and identify it as subject to recall; and
- Counting and return the product for disposal; or
III. Counting and disposing of the product themselves.
All products must be accounted for by recording what stock is retrieved and what stock (if any) is disposed by customers.
The picture above presents the main options for food disposal. The organization should consider returning the product to the supplier when his responsibility is proven. When the procedure guarantees conformity, reprocessing, re-labelling, or finding new uses for the product other than human consumption can be considered. The last resource is having the product destroyed.
- Monitoring the recall’s effectiveness
A recall must be monitored in every stage of the process. It is important to:
- Verify that the product has stopped been distributed and sold;
- Verify that the product has been returned to the designated places by the company;
- Assess the public response to the recall and, if necessary, repeat the press release using different methods.
6. Closing the recall
When the risk to the public is judged to be minimal and the company has taken all steps to assess the effective recall of the product, the process can be terminated. Staff and business customers should be notified of the recall’s termination.
- Post-recall reporting
After the organization has completed these steps, a final recall report should be prepared, which includes:
- The product(s) that was subjected to recall
- Evidence of identifying the recall extension and contacting costumers
- Evidence of food disposal
- Recall effectiveness
The organization should consider sending the report to local health authorities.
About the author
Nuno Soares is a food engineer who has been working in food industry since 1999. Nuno has worked in roles including quality and production manager. With the goal of reaching further with his ideas for food safety and support other professionals in their daily work, Nuno recently embraced researching and publishing activities. For his PhD, he researched how to improve frozen fish shelf-life and protection by developing a new glazing solution. After publishing his first book Food safety in the Seafood Industry (Wiley), he recently self-published the e-book: ISO 22000:2018 Explained in 25 diagrams.