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

Product Recalls: 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: Determine that a recall is needed. Identify recall personnel Evaluate health hazard Determine scope of recall p. 22, Directive 8080.1

Develop Recall Plan: Trace products in distribution. Determine scope of recall Trace products in distribution. Determine depth of recall Recall communications Determine effectiveness Returned Product Disposition Do recall simulations p. 22, Directive 8080.1

Procedure to Determine that Recall is Needed: Adulterated product Pathogen test results Consumer complaints Misbranded product Allergens not in ingredient listing p. 10

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

Evaluate Health Hazard: Any illnesses or injuries associated with product? Assess relative degree of seriousness. Assess likelihood of occurrence. p. 23 Allergens, p. 36

Recall Classifications : Done by FSIS/ODA Class I - reasonable probability that product will cause serious, adverse health consequences. Class II - remote probability Class III - …not likely... p. 23 Allergens, p. 36

Scope of Recall: How to determine amount & kind of product to be recalled adulteration - clean-up to clean-up? allergens - lot definition? p.23, Directive 8080.1

Tracing Products: 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 p.24, Directive 8080.1 Distribution records - use invoices Examples, p. 25

Tracing Products Requires: Sufficient product coding Record maintenance distribution records customers contact info, date of shipment, quantity Production records – trace back ingredients p.24, Directive 8080.1 Distribution records - use invoices Examples, p. 25

Depth of Recall: To whom product has been distributed? All consumers? Retailers and wholesalers? Only wholesalers? p. 26

Recall Communications: Describe method of communicating to customers phone, e-mail, fax, personal visit, etc. Follow up procedures for customers not responding. Identify product(s) subject to recall. name, code, package sizes, etc. Instructions on what to do with recalled products Contact information for customer follow up & questions. p. 26, 27

Public Notification: Describe method of public notification radio, TV, newspapers, store signs, direct customer contact, etc. Media contact information local TV & radio stations, newspapers, etc. p. 28

Public Notification 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 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: Verify that all customers received notification and have taken action. Maintain record of customer notifications and responses. p. 28

Effectiveness Checks: 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)? p. 28

Returned Product Control and Disposition: Means for controlling & disposing of returned products. Communication with inspection division. p. 29

Recall Simulations: 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 p. 29

Recall Simulations: Recall plan should be updated, based upon lessons learned from simulations. Results of simulations should be maintained. p. 29

Notify FSIS/ODA: 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 Amount of product affected p. 30

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

Emergency Management Directory 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