Food Recall Management: Overcoming The Big Obstacles

By Sam Lewis

Product recalls present absolute worst-case scenarios to consumer loyalty, sales, and the bottom line. As unfortunate as these events are, they can be managed. Jennifer McEntire, Vice President of Science Operations at the Grocery Manufacturers Association, took some time to answer my questions about how to efficiently and effectively handle a food recall.

Food Online: What are some best practices to prepare for a food recall?

McEntire: Don’t put your head in the sand and think that you’re never going to be impacted by a recall. Have a recall plan in place, and make sure it’s a living document. Test the recall plan using as many real-to-life scenarios as possible, and see if the recall plan is clear, user friendly, and identifies everyone’s roles and responsibilities. A once-a-year “check the box” mock recall is not going to adequately prepare you for real life.

Food Online: What is the most common reason for a food recall? What practices can food makers implement to help prevent that issue?

McEntire: Although outbreaks of foodborne illness capture the headlines, undeclared allergens actually top the list when it comes to the most common reason for a food recall. Food manufacturers need to have good label controls in place and make sure the right product is in the right package, ensure that the formulation didn’t change to include an allergen, and importantly, make sure that an ingredient supplier didn’t change their formulation to one that contains an allergen.

Food Online: What are the necessary steps in creating a recall strategy?

McEntire: The first step is building a recall plan. If done right (and practiced well), then follow the plan! A good recall plan needs to contain several key elements including:

• Identification of the recall team
• Triggers for convening the recall team and the decision making process
• How scope and traceability are determined
• How product disposition will be determined
• How communication will be handled and the timing of communication
  • To staff
  • To the Board
  • To the media
  • To customers
  • To consumers
  • To regulators
• A list of outside resources/experts
  • Attorney
  • Call center
  • PR firm
  • Laboratory

Food Online: Explain what recordkeeping/documentation practices food makers should execute during the recall process?

McEntire: There are two aspects to this: First, how to use documents you already have, that you should have been keeping, to help inform the recall decisions. These include documents related to production, sanitation, and traceability information. Then, there are the documents that are generated during the course of the recall. Meeting notes should be taken to document the decisions that are made, but they should remain factual and not speculative.

Food Online: How can food companies minimize damage a recall may have on their brand?

McEntire: Recall once and do it right. All too often we see recalls expand where additional products from a facility or additional production dates are included. This erodes confidence and can lead consumers to believe that the company doesn’t know what they are doing. It keeps the negative publicity going. The other thing is to truly put the consumer and their safety first.

Food Online: Where can food manufacturers and processors get more information and education on efficient and effective food recall management?

McEntire: GMA has a 1-day recall training coming up September 16 where I and my colleagues will share our knowledge and talk through some situations we’ve experienced. GMA has also put together a book on handling product recalls and withdrawals.  The USDA has a good guide on how to develop a recall plan, and although it is geared toward meat and poultry products, I find it more broadly useful. The FDA also has several resources, but I expect we may see more from them after the Preventive Controls Rules are finalized, because they will require that facilities have a written recall plan.

About Jennifer McEntire, Ph.D.
Dr. Jennifer Cleveland McEntire is Vice President of Science Operations at the Grocery Manufacturers Association where she oversees the microbiology, chemistry and packaging laboratories, process authority team, and consumer complaint product forensic analyses.

A food microbiologist by training, Jennifer’s areas of expertise include recall and crisis management, traceability, food defense, and food regulations. Jennifer was previously Vice President and Chief Science Officer at The Acheson Group, where she supported food industry clients through recall and crisis situations.

Prior to joining TAG, Jennifer served as the Senior Staff Scientist and Director at the Institute of Food Technologists (IFT). She also held a two-year appointment with the USDA’s National Institute for Food and Agriculture, and served as a visiting scientist at FDA CFSAN.

Jennifer earned a Doctor of Philosophy from Rutgers University as a USDA National Needs Fellow in food safety and received a Bachelor of Science with Distinction, magna cum laude, in food science from the University of Delaware. She was the 2010 recipient of the Rutgers University Food Science Alumni Association Communication Award and in 2012 was honored with the University of Delaware College of Agriculture and Natural Resources Distinguished Young Alumni award. She has also received two awards from the FDA CFSAN Center Director related to her work on food defense as well as food safety collaboration training materials.

She has authored more than 20 peer reviewed publications, six book chapters, and numerous white papers. She is on the Board of Phi Tau Sigma (the food science honorary society) and is a member of the Advisory Council of the Global Food Traceability Center.