If anyone knows what it’s like to go through a product recall, it’s Jeff Brechler.
Brechler, who handles sales and production for J&D Produce, Edinburg, Texas, received word a couple of days before Christmas in 2010 that salmonella had been detected in some parsley the company shipped to a Canadian retailer.
“It was a sickening feeling,” he said.
Fortunately, the company wasn’t at a loss for what to do next.
J&D already had an eight-person recall team in place and quickly put its recall plan into action.
The company turned an upstairs conference room into a command center, complete with laptop computers, telephones and fax machines.
“We were in constant communication with our customers, the Food and Drug Administration, field people and the PR firm,” Brechler said. “We were dedicated to running reports and getting information out to our customers as fast as we could.”
“There was dialog and interaction with all of our customers — those that were in involved and those that were not involved,” he added.
The good news is that that there were no confirmed reports of illness and no fatalities from the salmonella scare.
The company temporarily shut down its plant, virtually gutted the packing lines, plumbing and other equipment but found no sign of salmonella, Brechler said.
How or where the product became contaminated never was determined.
Brechler said the company’s recall plan worked pretty much as it should have.
The main thing that was not anticipated was arranging for the services of a public relations firm to field media inquiries and work with FDA to develop a press release.
The company did reach out to a PR agency after the incident was reported.
“They were very helpful and ready to assist with anything,” Brechler said. “It left us to deal with the problem at hand.”
On the right track
It appears that J&D Produce did all the right things.
A company’s response to a recall should begin well before a recall actually is implemented, said Amy Philpott, senior director at Watson Green LLC, Washington, D.C., a participating partner in the United Fresh Produce Association’s Recall Ready program.
Philpott said that when she reviews companies’ recall plans, the plans all too often begin with the decision to recall.
“It’s really important that companies understand there are steps before that decision is made that can help inform that decision (to recall),” she says.
The recall team typically consists of five to eight people who have decision-making authority and who understand the various business functions within the company, she said.
The team should include people representing grower relations, sales and marketing, operations and production, human resources, finance, legal, corporate communications, food safety, information technology and someone from upper management.
If necessary, consultants such as lawyers, crisis communicators and risk managers may be brought in, as well.
Assemble the team, share what information is available, then determine what more information is needed to make a decision, she said.
Once the decision is made, “you need to prepare to act, then act.”
“From there, it’s a loop,” she says, where information constantly is gathered and evaluated.
“You go through that loop continuously until you get to the end of the recall.”
After the recall, review, debrief and decide what lessons can be learned, she said.
Facts and figures
“Recalls are important because they represent the removal of contaminated or potentially contaminated product from the market, and a recall can help prevent an outbreak or help to stop one,” said FDA spokesman Douglas Karas.
The number of recalls of raw and processed produce has fluctuated over the past five years. Here’s a look at FDA’s most recent numbers:
2009 — 112
2010 — 220
2011 — 237
2012 — 559
2013 — 283
Several factors account for the variations, Karas said, including the amount of sampling done in a specific year.
If you’re involved in a recall, you’ll likely be dealing with the FDA more today than ever before, said Jim Gorny, vice president, food safety and technology for the Produce Marketing Association
In the past, the FDA could only “ask nicely” that a company recall its product, Gorny said.
Thanks to the Food Safety Modernization Act, “FDA has the authority to not only request a recall, but basically, they can recall product,” he said.
Preventing a recall in the first place should be a top priority, Gorny said.
Contamination can occur anywhere, he said, from the field to the packinghouse to retail establishments.
“Packinghouses are certainly an area where amplification can occur,” he said.
A small amount of contamination from the field can be spread across a wide range of products in a packinghouse and “make things a whole lot worse.”
Processing facilities also are places where special care has to be taken, Gorny said.
Preventing recalls basically means having a food safety program in place, he said.
That means implementing the good agricultural practices and preventive controls specifically delineated in the Food and Drug Administration’s Produce Safety Rule for the field.
In the packinghouse, good handling practices should be followed, and in fresh-cut plants, good manufacturing practices and Hazard Analysis and Critical Control Points programs should be in place.
All of those programs help identify the hazards and potential routes of contamination and provide an opportunity to develop preventive controls, Gorny said.
Third-party audits also can play an important role in staving off a recall.
“An audit provides a second set of eyes that isn’t necessarily familiar with you operation,” he said. “It can potentially identify vulnerabilities you may have.”
Brechler agreed that preparation is a key to surviving a recall.
Grower-shippers must lay out and monitor every aspect of their operations, from seed to harvesting, utensils used to harvest, cooling, packing, cold rooms and transportation, he said.
“If you notice a blip on the radar, you need to investigate and find out what it is, address it, move on and continue to monitor,” he said. “What that will enable you to do is to be able to defend your product.”
Any recall plan must be detailed, Philpott said.
“Oftentimes, plans identify what needs to be done, but they won’t identify who will do them and how they will be done,” she said. “Those are the details that trip companies up when they’re under pressure.”
Know whom to call at your customer’s location — it may be different from the buyer — and provide instructions about how to handle product in stock.
United Fresh will review a company’s recall plan on request, she said.
Philpott said she’s never been through a recall where daily business returned to “normal” in less than two weeks.
Injury claims, insurance or legal issues could go on for months or even years.
Brechler encourages all grower-shippers to take a proactive role in food safety by attending web seminars, training sessions and workshops whenever they’re available.
J&D continues to conduct two mock recalls during every seven-month season.
“It’s kind of like a fire drill in school,” Brechler said. “Make sure people don’t get lazy. Complacency is probably your worst enemy.”