One of the main elements of most third-party audits is an evaluation of recall and traceability programs. Auditors will generally ask to see the following information: a documented recall program and a documented mock recall program.
As part of the audit, the processor will usually be asked to conduct a mock recall. Typically, the auditor will select a product for a forward trace and an ingredient for a backward trace. If the company can find 99% of the products within two to four hours, the recall program will be judged acceptable. In this scenario, the processor knows when the audit will occur, so the staffing responsible for conducting traces is usually available.
However, few recalls or crises occur during a normal workday when all staff is available. Realistically, recalls often occur on a Friday afternoon before the start of a three-day weekend, during holidays or when management is out of the office for a meeting. These business realities mean every company must mandate several levels of staffing backup for managing recalls.
A recall is much more than finding product. Consequently, a mock recall should mandate that the production, quality and warehouse personnel collect all process, quality, food safety and sanitation records that pertain to the lot or lots involved in the exercise. Processors may grumble at the thought, but this mimics what is required in an actual crisis.
Another issue to consider during a mock recall is what many companies refer to as “stock adjustments.” For example, the records indicate 10,000 cases were produced. The plant’s workers can find 9,950, so they’ve managed to track 99.5%. Where are the remaining 50 cases? “Oh, stock adjustment,” they say. Were the cases removed as samples? Damaged in storage? Based on the numbers and the standards many companies set, the recall results were satisfactory. But if this were a true crisis with real potential for illness or injury, should these numbers satisfy you? I think not.
There are 50 cases and maybe as many as 1,000 individual units unaccounted for. This is one of the reasons recall programs must mandate a management review after each recall exercise or crisis.
The United Fresh Produce Association recently conducted a two-day workshop on crisis management that covered recalls and their importance. One of the points was that every person involved in any crisis must have a defined role. Not only must each role be clear, there must be training and practice to ensure each person understands his or her own role. In addition, the team must meet as a group and be trained to work as a team. It is absolutely imperative every company make time to ensure everyone knows his or her role in relation to other team members.
Training should roll down through all levels of the company, and there must be a mechanism to communicate with all employees. All personnel, from line workers to members of the crisis management teams, must understand the importance of communicating with the outside, especially with the media. However, only one or two staff members must be designated as the company spokespersons. Someone who is not authorized to speak on the company’s behalf can create serious problems.
Just as the Boy Scouts of America motto states, you must “Be prepared.” Train, educate and practice, practice, practice.
