MSU Extension

As new food processors move from the farmers market stalls into grocery stores, the need for documented plans regarding food safety becomes very important. The Food Safety Modernization Act has expanded the requirements for processing using HACCP-based food safety plans and procedures. While HACCP may minimize the food safety risk, it is not foolproof and the possibility exists that some food safety problem may arise after the product has left the control of its manufacturer. A good recall plan will minimize the liability risk to the processor and help to protect the public.

In developing a plan, several issues need to be addressed. First, who is responsible for managing the recall plan? After determining who is responsible, the complaint must be evaluated and the affected product must be accurately identified. Notifications must be made to parties who have an interest in the product, and the product must be removed.

Depending on the circumstance, the plan may be very simple or very complex based on the distribution of the product. A start-up processor with one product for sale in one store, in a small geographic market may have a plan that is only one page. Large processors, with multiple product lines, multiple distribution channels and many retailers will need a plan that deals with the complexity of their business. In any case, the processor should consider the aforementioned elements.

In the small company, the owner-operator is likely to be the recall manager, and in larger companies in addition to the recall manager, a recall team may be appointed, with roles related to their function within the company. For instance, a communications professional may be assigned to draft or review messages sent to the public and to regulators, while a HACCP manager may review processes in the facility and review production records. Choosing the right individuals and team are very important to the development and implementation of the plan.

The team should gather as much information as possible regarding the complaint about the product. The team should determine who is making the complaint and what is the nature of the complaint. The product should be identified using batch coding or some other method to determine the history of the product. The conditions of storage should be determined, as well as the date and location of sale. The team should also determine the extent of any illness or injury.

It is important to determine the identity of the affected products and have records that detail the distribution of the product. In the manufacturing process, batch numbers should be assigned with records indicating the date and location of manufacture. Each firm handling the product after manufacture should be identified. A timeline for the product traveling through the distribution chain should be established. Upon gathering this information, the recall team should make notifications. Typically, notifications are made to regulators, companies within the distribution chain and the public.

Once the decision is made to recall the product, the processor should make reasonable efforts to acquire control of the product. The key part in the removal of affected product is to segregate the product. This may mean offsite storage or separation from non-affected product by some kind of secure barrier. Companies in the distribution chain are encouraged to segregate affected product in their control. Affected products must be clearly marked and should not be sold. The processor should take steps to insure that the product has been properly disposed. In most cases, the product should be discarded; however, in some instances the product can be reprocessed or diverted to other uses such as animal feed. The processor must work with the regulators to determine the effectiveness of the recall and to determine when the recall should end.

Food processors who are taking their first steps into distribution should consider developing a recall plan. Extension Educators at Michigan State University Extension and Innovation Counselors at the MSU Product Center assist businesses in the establishment of good practices to improve business effectiveness. For further information and assistance with employee communications please contact your local MSU Extension office.