Growing Magazine - May, 2012
Are You Ready for a Recall?
Tools and tips for growers
Although many product recalls are voluntary precautions to allow further investigation, growers know that even a whisper of a food safety concern can spell disaster. A hint of isolated E. coli contamination in spinach can send consumers running from all leafy greens.
Advance planning has always helped producers cope with recall crises. For the 21st century grower, an ever-expanding arsenal of tools makes proactive management more effective than in years past.
It's no secret that recalls often represent relatively minor problems. A label may be incorrectly printed or a package slightly under standards. By alerting the industry, appropriate measures can be taken to remedy the situation.
Recalls fall into three classes. The United States Food and Drug Administration's (FDA) Class I involves factors that could seriously affect consumers' health. Foods containing botulinum toxin or undeclared allergens fall into this category. Class II recalls indicate a less serious or temporary impact on health. Class III recalls are used for container and labeling problems that are unlikely to result in medical difficulties.
FDA and county inspectors check to see if food products are at least 6 inches off the floor, and there is no sign of mold, rot or rodents.
PHOTO COURTESY OF THE USFDA.
At this time, the majority of recalls are voluntary. Newer and future regulations could make mandatory FDA recalls more common.
Whether a recall is based upon a technicality or a serious health concern, the damage to growers can be equally great. No one is immune to being involved in a recall at some level.
"In a commodity-based industry such as the produce industry, you are guilty until proven innocent," says Gary L. Fleming, vice president, strategic services, for RedLine Solutions (www.redlinesolutions.com). "As such, if a commodity is implicated in a recall and you sell that commodity, it is very likely that your product will be pulled as well until such time you prove yourself to be innocent."
To minimize the possible adverse consequences, several proactive steps may be taken. Planning, tracing, insuring and communicating all play a part in recall risk management and preparedness.
FDA mobile lab analysts prepare to test produce crossing the border for Salmonella and E. coli. Mobile laboratories help the FDA quickly test food and drugs for contaminants.
PHOTO COURTESY OF THE USFDA.
Be proactive with planning
While good agricultural practices and good handling practices cannot eliminate the possibility of a recall, they can help reduce the risk. Specific methods apply to various commodities, while some standards are virtually universal. Points to consider include ...
- employee health and hygiene;
- prior land use;
- input programs, including fertilizer and pesticides;
- sanitation of equipment and facilities;
- proper harvesting and storage methods; and
- water use, including irrigation and postharvest cleaning.
Growers doing everything right may still find themselves in a recall situation. In order to be prepared, develop a recall plan. You may even consider holding a mock recall to iron out the wrinkles and build confidence.
The recall team should include the owner or top official of the operation. High-level decisions may be required at a moment's notice. A person on top of quality assurance and/or food safety is needed, as is an expert on production operations. Include someone who can track product quickly and has full access to all records. A salesperson can be helpful in contacting customers. Legal representatives and communication specialists round out the group.
Avail yourself of existing training and resource opportunities. Many organizations such as growers' alliances and government agencies offer workshops. Guidelines developed by such authorities as The Leopold Center in Iowa (www.leopold.iastate.edu) and North Carolina State University (www.ncsu.edu) may be accessed online.
Follow the food
Recalls are particularly frustrating for growers due to the nature of the produce industry. Various fruits and vegetables are produced in different regions under different conditions. Growers know that "an apple is not an apple" - a problem in one orchard does not translate to difficulty in every apple operation.
However, consumers, retailers and wholesalers may not make the distinction or may be unwilling to take a chance. Since many produce items are not branded, it has been difficult to show that problems such as contamination are not universal across a product category.
The Produce Traceability Initiative (PTI) is seeking to change that. The produce industry's proactive approach, dating back to 2007, is rooted in the notion that food can be followed all the way from the field to the supermarket. While most growers have internal traceability - knowing which personnel, fields, harvesters, storage buildings and similar facilities are involved in crop production - in place, the more universal whole-chain traceability concept moves beyond the farm. Whole-chain tracking can show that a shipment of lettuce came from a particular farm and further indicate the steps along the way. When the entire industry is on board, widespread recalls of a particular crop may be less common.
"Having a whole-chain traceability process will not only minimize the amount of product you would need to pull if your commodity is found to be the cause, but will also help you prove your innocence faster and get your product back into commerce," Fleming explains.
Leafy greens are among the more commonly recalled produce commodities.
PHOTO COURTESY OF THE USDA AGRICULTURAL RESEARCH SERVICE, SCOTT BAUER.
The now voluntary traceability project ties with the 2002 Bioterrorism Act and 2011 Food Safety Modernization Act, helping to protect growers, shippers, wholesalers, retailers, processors and consumers. The PTI involves labeling products with information identifying its path along the supply chain.
To get started, producers obtain a GS1 company prefix to identify their operation and a Global Trade Item Number to identify products at all packaging levels. GS1-128 bar codes pinpoint additional data, such as lot numbers and usage dates. Produce identified with this machine-readable data, along with human-readable information, can accurately reflect sourcing. Thus, a specific item can be ruled in or out of a potential recall situation.
Fleming, whose company does offer PTI products and services, says it is important to engage a provider who is compliant and has all the tools in place today. In addition, an ideal provider has successful produce implementation experience in both low and high-technology settings.
Additional resources for implementation and technology providers is available on the PTI website: www.producetraceability.org.
Protect your product
In the event that produce from your farm is involved in a recall, appropriate insurance can help mitigate the damage to your bottom line. Although consultation with your insurance and legal advisors is needed, the North Carolina Cooperative Extension Service (www.ces.ncsu.edu) suggests that growers consider several types of policies in addition to general liability. Specialized insurance, unlike general liability, provides risk management for off-site occurrences. Commercial business liability coverage may be valuable for operations that process fresh produce or sell at farmers' markets.
Product liability insurance picks up where general liability leaves off - away from the farm premises, where claims of injury from contaminated produce may occur. Retailers may require this coverage in the event of consumer claims. To protect your operations from the direct costs of a recall, investigate product recall insurance. This coverage may compensate for such expenses as removing, transporting and replacing suspect products. However, claims may be denied if the recall is general and not tied directly to your operation. Thus, the importance of traceability is underscored. Accidental or product contamination policies may protect against both direct and indirect costs.
In cases that are criminal, malicious tampering policies come into play. Such coverage may compensate for recall expenses, lost profits, rehabilitation costs and crisis response.
Combination and supplemental policies are offered as well. In addition to these options in the private insurance marketplace, some Federal Crop Insurance programs may be considered in an overall recall-readiness plan.
Communication is key
If you need to implement a recall, burying your head in the sand may be appealing, but upfront communication is a key component for crisis management. In addition to traditional media, today's social media and instant news means that word spreads more quickly than ever. FDA recall notices are even available through Twitter and mobile phone applications.
Making your food safety program a regular part of your communications and company image can strengthen your position. Be proactive in letting the marketplace know how you are providing quality products. Church Brothers Produce (http://churchbrothers.com), for example, clearly outlines both its food safety program and recall process on its website. Specific contact persons and telephone numbers are included.
Initially, communications will likely involve alerting company officials, key clients, the FDA and the media. An extensive contact list including information for off-hours will facilitate the process.
A communications person on your recall team may prepare ready-to-use documents that can be updated and quickly deployed. Sample press releases and letters are available online at: www.fda.gov/Safety/Recalls/IndustryGuidance/default.htm. Designate spokespersons for the media. A dedicated staff person and/or telephone number to address inquiries from both industry partners and consumers may be appropriate.
Getting ready for a recall is no easy task, but advance planning and preparation can save the day if a difficulty arises.
Based in Greensboro, N.C., the author writes articles about horticulture, landscaping, agriculture and travel. She has been a contributor to Moose River Media publications for five years.