By Charles Breen
This month’s Ask the Expert is on how to prioritize planning for food safety emergencies, particularly in light of the challenges of not only the emergency itself but recovering from it with your company’s reputation intact. It is answered by Charles Breen, EAS Independent Advisor for FSMA and Stacey Stevens, a Senior Vice President at FoodMinds, a division of Padilla. FoodMinds is EAS’ newest cooperative partner, and together our services help our clients working in the food industry to tackle regulatory and public relations challenges.
Question: As part of FSMA I am working to develop our company’s food safety contingency plans. How do I prioritize and plan for the first steps we need to take – investigations, recall communications and managing our public relations?
Answer: Great question and one worthy for all companies to consider, especially, as you point out on the regulatory side, FSMA mandates include both a hazard analysis risk assessment and if hazards in need of control exist, a recall plan. In addition, every company strives to mitigate harm to its reputation in the face of public scrutiny. So, how does one go about developing a comprehensive plan and assigning tasks on both sides of the coin? First, on the safety front:
In the interest of public safety, whenever a food safety issue has been reported, whether by FDA, another food safety authority or the public, unless you can unequivocally rule out your product as the culprit, initiate a recall. While the FDA and other food safety authorities could be wrong, they very rarely are. This will help to limit further harm, particularly in the case of Class 1 recalls which have a high likelihood of injury or death. Make sure management, as well as legal representatives, are informed of the decision to recall.
Next, per regulation, file a Reportable Food Registry report on FDA’s website. This must be completed within 24 hours of learning of the problem. It’s OK to have incomplete information to start, you must update the file as more information becomes available.
Keep good records and implement your Trace Back and Trace Forward action plan – match ingredients and sources with bills of lading so that you can attempt to identify the source of the problem. Establish the last documented evidence before the problem arose, the time the problem became known, and documentation that it was controlled. You’ll also need to identify recipients of the product and alert them directly. If those recipients cannot be accurately identified, the recall will grow exponentially larger, more expensive, and harder to manage.
Next, on the communications front, remember to take control of the messaging and communicate early and often. The public will want to know what you are doing to protect them now and how you will do things differently in the future. Be empathetic, forthcoming, and express an understanding of the seriousness of the situation. Don’t forget social and on-line media, websites and microsites – post brief updates in real time to keep everyone informed from line employees to key stakeholders and consumers.
In many cases, companies involved in a food safety emergency will enlist the assistance of qualified and experienced third-party consultants to help them through the crucial regulatory and safety steps as well as strategic public relations messaging.