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

2. 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.

3. Recall Plans Include Procedures to:
Determine that a recall is needed.
Identify recall personnel
Evaluate health hazard
Determine scope of recall
p. 22, Directive

4. 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

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

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

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

8. 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

9. 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

10. 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
Distribution records - use invoices
Examples, p. 25

11. 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
Distribution records - use invoices
Examples, p. 25

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

13. Recall Communications:
Describe method of communicating to customers
phone, , 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

14. 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

15. 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)

16. 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

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

18. 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

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

20. 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

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

22. 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

23. 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

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

25. 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