Mock Recalls: Highly Encouraged
Let’s spend some time addressing a topic that not one single food manufacturer or distributor enjoys discussing: product recalls. Let’s face it, a product recall could be one of the largest headaches your company has to face, but if completing a smoothly operated and well-organized recall means no consumer gets ill or passes away, it is worth the preparation and action.
Mock recalls are a vital part of your company’s food safety chain. The way you plan for an event, such as a recall, will determine how the event will go in the case of a time-sensitive emergency. To begin, “what is a mock recall, and why do we need to do one?” Jumping right in, a mock recall is a test run at carrying out a product recall and a way of finding the insufficiencies in your written recall plan. During a mock recall, a consultant or simply your facility manager will oversee the process of what a specific product recall would look like. The overseer will take a good look at your recall team -who you have assigned to each task, they will double check the phone numbers and contact information for your U.S. Food & Drug Administration (FDA) representative, the statement you would release to the public, etc. Ultimately, they will make sure that your facility would be able to smoothly execute what your documentation outlines without straying from your written food safety and recall plan.
According to the Food Safety Modernization Act (FSMA) Final Rule for Preventive Controls for Human Food: “If the hazard analysis identifies a hazard requiring a preventive control, the facility must have a written recall plan that describes the procedures to perform a recall of the product. The recall plan must include procedures to notify consignees, to notify the public when necessary, to conduct effectiveness checks and to appropriately dispose of recalled product.”
A mock recall can be conducted as a scheduled event or as a surprise to the facility employees. Of course, there are advantages to both. Scheduling your mock recall will ensure that you’ve organized your documentation to the best of your ability, and can run the mock recall with absolutely no surprises or hiccups. This will be your “best case scenario” situation. However, springing a surprise test of your emergency preparedness system will give you a more accurate representation of how equipped your facility is for an emergency recall. Think of this as your stress test – you’ll find the holes your recall team’s plans that may not have caught in a controlled, scheduled test. It is entirely up to you which plan of action you’d like to take.
Document everything! We at connectfood.com cannot shout this statement loudly enough from the highest rooftops! As you’ve read in prior posts from us, CEO Matthew Botos frequently says, “If you didn’t document it, you didn’t do it.” This includes your mock recall testing. Record it all – what went well, what did not go so smoothly, the original plan, and the newly edited documentation. Being able to provide documents describing your emergency planning to an FDA inspector during an audit will keep your company compliant with the requirements of your written food safety plan. The FDA released an updated set of requirements in May 2018 regarding recalls, which can be found here. This regulatory procedures manual outlines exactly what your facility needs to have prepared as part of your written recall plan. This manual may be 87 pages long, but it is necessary information for your food safety manager and recall team to be familiar with. Review and get comfortable with what is required as a part of your recall plan – this is what you will assess during your mock recall.
Though FSMA does not require a mock recall as part of your written food safety plan, take a moment to think of the chaos your facility could avoid by choosing to get ahead of the issue. Brian Honigbaum of Quality Assurance Magazine says “practice makes perfect” in his article on mock recalls, and he is absolutely correct. The more effort and seriousness you put into your mock recall, the more prepared and confident your facility will be in the case of initiating and carrying out a product recall. Recalls are high-pressure situations, but you can be prepared to handle the stresses and surprises with a bit of preparation.
Want more information on recalls? Dr. Kathy Knutson, Ph.D., Lead Instructor for Preventive Controls for Human Food (PCHF), Preventive Controls Qualified Individual (PCQI), wrote a series of “Recalls: Lessons Learned” blogs for connectfood.com last summer just for you! Check them out here: Part 1 & Part 2.
connectfood.com can help you get your recall team, hazard analysis, and recall documents organized and in place. If you need assistance with any of these items or would like to schedule a consultant to conduct a mock recall for your facility, contact us. We are here to help you achieve the utmost food safety status.
About the Author
Johanna Seidel, PCQI
Johanna Seidel is an administrative member of the ConnectFood team, where she works as manager of operations and manager of social content. She is a certified Preventive Controls for Human Food Qualified Individual (PCQI). She received a Bachelor of Fine Arts Degree from West Texas A&M University in 2016. When she is not working food safety, Johanna also works as an instructor for The Chicago School of Ballet.