Recall Management

Recall Management 

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How food and beverage companies are rethinking crisis management amid COVID-19

The pandemic demands a holistic approach to managing risk that goes well beyond increased product safety measures.

A watershed moment for the food industry

The COVID-19 pandemic has brought the critical nature of the global food manufacturing industry into clear focus and highlighted the essential role that food and beverage producers play in the maintenance of public health. While the impacts of the virus have been felt across all sectors, food and beverage manufacturers—whose essential operations have continued throughout the duration of the evolving crisis and whose products have distinct health and safety considerations—face unique and acute challenges. 

Despite having crisis management and business continuity plans in place, many in the food industry have found themselves ill-prepared to handle the multifaceted impacts of the pandemic. Challenges around rapid shifts in market demand, staffing and social distancing, changing regulations and supply chain integrity have underlined the need for a resilient approach to product risk management. 
Organizations have a pivotal opportunity in this moment to reframe their plans and processes for food safety, crisis management and business continuity. Consider the following ways that food and beverage companies are meeting the challenges of the COVID-19 crisis and building long-term resilience:


1. Scenario planning

Widespread panic and uncertainty during the COVID-19 pandemic has generated a surge and shift in demand for food products, rendering useless the forecasts that manufacturers previously created regarding enterprise resources and material requirements—everything from supply (of packaging, raw materials and ingredients) and staffing needs to distribution and logistics. Companies must be prepared for second and even third waves of this pandemic as well as other unforeseen events.  

Scenario planning is crucial as companies aim to remain resilient through the COVID-19 crisis and beyond. Companies should consider conducting a holistic risk analysis and business impact analysis including factors related to a pandemic. By organizing their crisis management teams to assess the “what ifs” and determine all possible impacts, companies can begin to structure a sound strategy to address the challenges and mitigate the fallout of the COVID-19 crisis and other unforeseen crises. Conducting a “crisis within a crisis” simulation exercise will test the adequacy of an organization’s crisis, recall and business continuity plans and assess the capabilities of its people, processes and systems under strained conditions.


2. Maintaining a culture of safety 

The impacts of the COVID-19 pandemic have resulted in a reduction in work force due to illnesses, quarantine, anxiety and fear of returning to work. Simultaneously, manufacturers are operating at the capacity created by the surge and shifts in demand. To combat these concerns, manufacturers are temporarily moving untrained people into new roles or hiring temporary help. This impacts efficiency, quality and potentially food safety through mistakes in manufacturing or a potential lack of proper process controls, leading to a higher risk of a product recall incident.

To minimize this risk, it is essential to maintain a food safety culture by ensuring all workers receive proper training to obtain an effective understanding of good manufacturing practices and food safety measures. Readily available webinars, online training and virtual exercises on a variety of good manufacturing and food safety topics are ways to allow workers to get the vital training they need without overly imposing on schedules or resources. Having a third party conduct a food safety culture assessment offers insight into areas needing immediate attention as well as corrective actions.  


3. Establish robust monitoring systems

While close contact can occur anywhere in food manufacturing environments, social distancing is especially difficult  on production lines where workers are typically within inches of one another. Manufacturers have slowed lines and distanced workers as much as feasibly possible but production facilities running at full capacity may not be able to follow social distancing guidelines to the fullest extent. 

Manufacturers have enhanced their food safety measures, stringent hygiene practices and sanitation schedule frequency. Establishing robust monitoring will be a key part of mitigating the risks of exposure and tracking any infection-related trends. Some of these actions may include:

  • Screening everyone for COVID-19 symptoms and exposure before entrance to the premises 
  • Changing traffic patterns in the facility to reduce exposure to others
  • Altering production, shift and break schedules to minimize crowding
  • Adding face masks, shields and gloves to required PPE and providing proper use training
  • Ensuring adherence to enhanced hygiene and sanitation procedures

During the COVID-19 crisis, it is especially critical that companies assign dedicated monitoring resources to constantly manage new control measures at every stage in food manufacturing, processing and handling to keep their workforce and customers safe.


4. Sustaining regulatory compliance

Food producers need to remain current and compliant with complex and ever-evolving regulatory requirements precipitated by the COVID-19 pandemic, which has created unprecedented uncertainty and confusion in dealing with legal liability and regulatory compliance consequences. 

To maintain compliance with regulatory and best practice food safety measures, it is important that food manufacturers concentrate on reviews of current good manufacturing practices (cGMP), food safety management systems (FSMS) and hazard analysis and critical control points (HACCP) programs to ensure current practices are effective. While on-site audits may not currently be possible , some certification bodies are offering extensions upon meeting specific criteria. Non-standard remote or virtual audits may be conducted but do not replace standard audits for certification purposes. Impartial third-party audits, assessments and document reviews focus on ensuring gaps are addressed and additional preventive controls and corrective actions are implemented as needed.  

Food regulatory agencies have stepped up to help the food industry by establishing guidance documents available on their websites to help companies navigate the temporary changes in regulatory requirements due to the COVID-19 crisis. Companies should refer to these guidance documents regularly to ensure they are compliant with the most recent changes in the regulatory landscape and are up to date on food safety measures.


5. Building a resilient supply chain

Every step in the supply chain from farm to fork has been impacted by the changes brought about by the COVID-19 crisis. The availability of products, affected by products held at ports or delays in transportation, has strained suppliers and manufacturers. Some suppliers are finding the increase in demand for their products overwhelming.  

One way to address this issue is that suppliers may work to diversify their customer base and increase customers in close geographical areas where possible, thereby minimizing delays at ports and borders. Likewise, as supplier contract renewals come up, manufacturers will be looking to diversify their supply chains and bring suppliers closer to home to avoid the challenges and disruptions they are currently facing.    

In addition, the temporary suspension or modification of regulations and routine inspections makes it that much more important for companies to increase supply chain surveillance and ensure the receipt of high-quality, safe products and ingredients. This is an opportune time to review supplier contracts and take measures to ensure that alternate suppliers are available or to consider other options.  

A risk assessment to consider all risk dimensions along the entire supply chain is necessary to implement prompt controls and make changes in policies to address areas of vulnerability. Assessments and reviews of supplier management programs, identification and training on critical risks and preventive measures along the supply chain, and documenting all changes and process flows are some ways to validate vulnerabilities are addressed effectively


Readiness, response and recovery

As the risk landscape evolves through the COVID-19 pandemic, businesses will have to consider what the “new normal” will look like and what permanent changes may be necessary to operate a safe and clean environment. As food companies address changes in regulations, revamp their sanitation practices and renovate and restructure their operations, they have an opportunity to holistically assess the risks to their business and build a strategy for crisis readiness, response and recovery that allows for resilience through the pandemic and into the future.

Notable recalls in 2020

Onions and products containing onions

In July and August 2020 an outbreak of Salmonella affecting 15 US states was linked to onions and products containing onions produced by Thomson International and distributed through several retailers nationwide.

Frozen shrimp

Various frozen cooked, peeled and deveined tail-on shrimp distributed by Kader Exports and sold under various brand names at large grocery chains between February and May 2020 were recalled due to Salmonella.

Wegmans citrus and other products

Wegmans recalled oranges, lemons and a variety of in-store produced seafood, as well as any in-house restaurant food that contained fresh lemon, due to Listeria contamination.


Peaches packed or supplied by Primo Wawona or Wawona Packing Company from June 1 through August 3 were recalled for Salmonella.

Trend analysis

2020 US Food and Beverage recalls by category

Source: USDA & FDA

In the first eight months of 2020, fruits and vegetables have been subject to more recall actions than any other food and beverage category to date. They are followed by nuts and snack foods, and dietary supplements.

Fruits and vegetables were recalled primarily for pathogens; in particular, Salmonella, Listeria monocytogenes, Cyclospora and E.coli.  In addition, there were several recalls for fruits and vegetables containing sulfites or multiple undeclared allergens.

The majority of the recalls concerning nuts and snack foods were for undeclared allergens and only a few were for Salmonella, Listeria monocytogenes or E.coli.

In the dietary supplements category two recalls were for unsubstantiated health claims and unapproved ingredients and all other recalls in this category were due to Salmonella or other undeclared allergens.

The remaining food and beverage categories were recalled for undeclared allergens, pathogens, regulatory violations or foreign material.

2020 US Food and Beverage recalls by reason

Source: USDA & FDA

In the first eight months of 2020, there were a total of 309 FDA-regulated and 23 USDA-regulated food and beverage recalls; most products affected were distributed nationally. A little over 89% of these recalls were attributable to foods adulterated with pathogens (37%) and undeclared allergens (52%). These are the same top reasons for food and beverage recalls that have been reported the past couple of years. 

It is noteworthy that the number of recalls in March and April far exceeds any other months in 2020 to date; however, there was no discernible reason for the increase. In the pathogen category, Salmonella and Listeria monocytogenes were the leading factors for recalls.  Milk, tree nuts, peanuts and products with multiple undeclared allergens topped the list in the undeclared allergens category. For USDA recalls, eight of the total 23 recalls were due to lack of proper inspection or import re-inspection. 

After April, there was a decrease in the number of recalls which may be aligned with the decrease in regulatory scrutiny and oversight, and the temporary relaxing of some regulations due to the COVID-19 pandemic. We may see the fall-out of these actions in the months to come.

Mitigation strategies

Undeclared allergens are the leading trend in food and beverage recalls. Manufacturers can take several steps to mitigate a recall for undeclared allergens by:

  • Reviewing and updating allergen control program
  • Reviewing product specification sheets and ingredient statements
  • Properly training all plant personnel on allergens and cross-contamination
  • Checking labels before a line changeover  or when there is a change in recipe or formula to ensure that the right label is on the right product
  • Removing or destroying old or obsolete labels in inventory
  • Clearly marking and segregating old ingredients or blends still in stock to avoid accidental use
  • Keeping regulations and best practices concerning allergens up-to-date
  • Reviewing ingredients and products received from suppliers and co-packers
  • Communicating any changes in ingredients, formula, processes or systems to all necessary audiences

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