Developing a Recall Plan for Meat and Poultry

Developing a Recall Plan for Meat and Poultry Products Lynn Knipe Ohio State University

Product Recalls: l l Removal of products from commerce to protect public from consuming adulterated or misbranded products. Alternative to regulatory detention or seizure of adulterated or misbranded products.

Recall Plans Include Procedures to: l l l Determine that a recall is needed. Identify recall personnel Evaluate health hazard Determine scope of recall Evaluate health hazard

Develop Recall Plan: l Determine scope of recall l Trace products in distribution. Determine depth of recall Recall communications Determine effectiveness Returned Product Disposition l Do recall simulations l l

Procedure to Determine that Recall is Needed: l Adulterated product • Pathogen test results • Consumer complaints l Misbranded product • Allergens not in ingredient listing

Identify Recall Personnel: l Coordinator - Internal & external employees • Contact information • Determine communication process & practice

Evaluate Health Hazard: l l l Any illnesses or injuries associated with product? Assess relative degree of seriousness. Assess likelihood of occurrence.

Recall Classifications : l l Done by FSIS/ODA Class I - reasonable probability that product will cause serious, adverse health consequences. Class II - remote probability Class III - …not likely. . .

Scope of Recall: l How to determine amount & kind of product to be recalled • adulteration - clean-up to clean-up? • allergens - lot definition?

Tracing Products: l l l Define product lots so that products can be positively identified in the event of a recall. Trace back – one level Trace forward – begins when any component enters establishment

Tracing Products Requires: l l Sufficient product coding Record maintenance • distribution records – customers contact info, date of shipment, quantity • Production records – trace back ingredients

Depth of Recall: l To whom product has been distributed? • All consumers? • Retailers and wholesalers? • Only wholesalers?

Recall Communications: l Describe method of communicating to customers • phone, e-mail, fax, personal visit, etc. • Follow up procedures for customers not responding. l Identify product(s) subject to recall. • name, code, package sizes, etc. l l Instructions on what to do with recalled products Contact information for customer follow up & questions.

Public Notification: l Describe method of public notification • radio, TV, newspapers, store signs, direct customer contact, etc. l Media contact information • local TV & radio stations, newspapers, etc.

Public Notification l Includes: • Company name, address, contacts and phone numbers. • Indicate voluntary recall, product may be contaminated with L. mono. , and if no one has been reported ill. • Product description (lot #, date), stores • How problem was discovered (routine monitoring by company, ODA or FSIS)

Public Notification l l l Responses to media questions should be made ASAP. One company spokesperson should be selected. Focus on “talking points: ” • • company concern a voluntary recall cooperating with ODA/FSIS problem is fixed

Effectiveness Checks: l Verify that all customers received notification and have taken action. • Maintain record of customer notifications and responses.

Effectiveness Checks: l Determine if all product is accounted for. • How much product needed to be recalled? • How much was shipped and to whom? • How much was returned, destroyed or irretrievable (consumed)?

Returned Product Control and Disposition: l l Means for controlling & disposing of returned products. Communication with inspection division.

Recall Simulations: l Method for determining the ability of recall plan to control or retrieve product in question, as quickly as possible. • Randomly select a lot of product that has been distributed for simulation

Recall Simulations: l l Recall plan should be updated, based upon lessons learned from simulations. Results of simulations should be maintained.

Notify FSIS/ODA: l l Contact FSIS/ODA within 24 hrs of determining need for recall. Be prepared to provide: • Identity of product – lot identification needed • Description of deviation, date and circumstances l Amount of product affected

Recall Oversight: l l If firm initiated – FSIS/ODA reviews establishment recall strategy If FSIS/ODA notifies firm: they confirm in writing, FSIS/ODA’s determination of need • specify violation, classification, recommended recall strategy

Crisis Management l l l Emergency action plans (advanced preparations) related to: Adulterated product Natural disasters • floods, tornadoes, fires, power outages l Tampering, bomb threats, etc.

Emergency Management Directory l l Prepare ahead, so it is accessible in emergency. Names and phone numbers: • regulatory contacts • media contacts - TV, radio, newspapers • key customer contacts • accredited testing labs • police & fire departments