Two thirds of recalls are down to poor allergen management or labelling. Time to let technology ease the irritation of allergen management...

Rick Sanderson FIFST - Managing Director, Gate to Plate Compliance

Rick has served the food industry for 25 years. Some of his previous roles include being the Head of Food & Agri at M&B, Head of Technical Support Services at SAI Global, and has worked in Senior Procurement & Commercial Roles in large EU/Global food manufacturers in Tulip, Grampian, Produce World and First Milk, as well as building his own food companies. During this time Rick experienced full recall issues around pathogens, mislabelling, and foreign bodies, and has been on the front line to mitigate the subsequent impact with customers and stakeholders.

Stephen Whyte – Managing Director, QADEX 

Stephen has spent 25+ years in the food industry, with senior roles in Kerry Foods & Samworth Bros, before founding QADEX. It has grown steadily to a team of over 70 hard working and dedicated professionals committed to supporting over 14,000 food manufacturing sites globally, helping them to enable step change improvement in food safety and brand protection through cloud-based technology.

What are the facts? – Almost two thirds of recalls are down to mislabelling, 59% of those allergens

Reasons for Recall 2018 – Source: data.gov.uk

The top 10 possible reasons behind the recent increase in food safety recalls? 

1.      Poor product level data & specification management

2.      Enhanced capability to detect the issues - discovery of issues previously gone undetected

3.      A more complex ingredient mix leading to label confusion

4.      A more complex global supply chain - longer product travel, through more hands, higher risk of temperature abuse & greater risk of contamination

5.      Lack of transparency in food chains - greater impact of recall due to inability to pinpoint origin

6.      Inadequate clear down & segregation processes in food factories

7.      More processed food – handled by more people & machines leading to greater risks

8.      Lack of investment in technology solutions

9.      Exposure to greater manure, chemical & pollution risks in the agri-chain

10.  Paranoia from manufacturers around allergen contamination

Are businesses becoming more cautious when considering a product recall? If so, what is behind this caution? Could it be linked at all to the growth in demand for free-from foods and recent high profile allergy-related deaths?

It’s to be expected that food manufacturers are going to become more cautious when it comes to recalls in relation to allergens. The consequences are immediate, identifiable and as we have seen in recent cases, potentially tragic.

The probabilities of cross contamination are much higher in modern food manufacturing environments given the nature of diverse ingredient decks and manufacturing processes, so caution is to be advised, and can steer decision making when it comes to recall. Better to be safe than sorry.

What impact can a recall have on a business?

●       Financial impact - Lasting effect on a small business, cash flow concerns, and in the worst case, bankruptcy. The Grocery Manufacturers Association claim that the average product recall can cost a food manufacturer €10m in direct costs

●       Brand Degradation and Reputational Damage - Consumer research revealed that 55% of people would switch brands following a recall, even if only temporarily

●       Damage to consumer loyalty - The same research highlights that 15% of consumers would never purchase the recalled product again. The wider impact was also demonstrated, with 21% of those surveyed stating they’d actively avoid the full product range made by the manufacturer at the centre of a recall

●       Delisting at Retail

●       Stock Value Loss - I.e. Drop in share equity and stock disposals

●       Large business can generally withstand financial impact and possible brand damage, and survive. For example, the Volkswagen emissions scandal

How can the business move swiftly to minimise the impact from a recall?

It has been proven that swiftly dealing with a recall, compensating consumers, and managing PR well, can rebuild trust in a product or brand. In fact, if handled well, consumer trust in the wider brand can be rebuilt or even maintained, if handled swiftly and correctly.

Ten steps to manage and mitigate the damage of a recall 

1.      Act decisively internally and ensure all senior level stakeholders are in agreement with the course of action, establish a dedicated cross functional team, and confirm that all areas of the business are aligned with the decision to recall

2.      Develop a plan and stick to it

3.      Complete an impact assessment internally, and have some measure on the external impact. Trace the product, if possible, upstream and down the supply chain.

4.      Act swiftly and ensure consistency in communication and message, coming from the appropriate individuals within the business

5.      Immediately notify regulators and cooperate with them throughout

6.      Immediately notify customers of the potential issue, engage the public and immediately disclose all relevant recall and replacement information as soon as possible

7.      Compensate the customer - Recall, Repair, Replace or Refund with immediate and clear pathways to act

8.      Immediately notify staff and all internal stakeholders of the situation, remedial action and likely outcomes - you may well need them for extra production, flexible hours, and preventing bad PR/rumours emanating from the shop floor

9.      Apologise and acknowledge the problem, consistently, to all stakeholders involved. Communicate openly with all parties about the issue

10.  Do all possible to mitigate stock loss and impact on the ultimate consumer. Consider collaborating with competitors to mitigate damage to the customers and wider category. They may have equivalent stock or solutions to solve the immediate issue

How can they minimise the risk of it happening again? What new technologies are out there to help them do this? Does preventative maintenance play a part? How important is a good food safety culture?

There are in fact three phases to a recall – Before, during and after. After is almost the most important phase, and can make a lasting impact and ultimately build a more robust business.

Ten steps to minimise the risk of a recall happening 

1.      Inspiring people to do the right things, at the right time. Food safety culture is paramount. BRC v8 specifies that senior management ‘shall define and maintain a clear plan for the development and continuous improvement of food safety and quality culture’. Having a strong food safety culture is central to preventing product recalls. With the root cause of many food safety issues being human error, the focus has to be on people and cultural and behavioural change.

2.      A full and professional post-mortem after the event of a recall, to seek out route cause and learn from the findings. This has to be open, honest, and findings must be reviewed without prejudice or consequence, otherwise results are not true

3.      Design a resolution plan based upon the findings of the inquiry

4.      Design robust systems to handle future recalls. Identify potential enhancements in recall ability,such as teams, technologies, and processes. Incorporate recalls into corporate crisis communications plans

5.      Develop, document and continually enhance a recall manual

6.      Stage mock-recalls regularly, and honestly appraise outcomes/seek improvement

7.      Complete regular traceability exercises and ensure confidence in the process

8.      Preventative measures such as total quality management and regular product testing

9.      Consider product safety, recall and traceability during the NPD process

10.  Labelling is the main cause of issues. Ensure that the correct labels are applied to products and any outer packaging. Packaging should be removed and destroyed at the end of a production run as best practice. 

Take the first step towards less allergen based irritation -

For more information on how we can help you with your allergen management and labelling challenges, and to see how technology can be the enabler, watch this short video...

To find out more contact Rick Sanderson [email protected] or Stephen Whyte [email protected]