Risk Management Consulting, LLC

Food and Beverage product recalls have proliferated in the past few years, leading many consumers to question the integrity of growers, manufacturers, distributors, retailers and regulators.  Unfortunately, many companies continue to be unprepared to conduct rapid and appropriate operations and communications when a recall is required.

Too many companies “play ostrich” about the possibility of a recall.  Instead of preparing in advance, they wait until a recall is inevitable and then try to figure out what to do, resulting in additional risk for consumers and the company’s reputation.

10 Key Product Recall Considerations:

1. Rapid response to a known product problem minimizes both economic and reputational damage. The time to examine the systems you have in place for recalls is now, not when you already have a product needing recall.
2. Have a product recall plan ready to use that covers all operational, legal and communications (internal and external) components of making a recall. "We'll wing it" is not a product recall plan.
3. Have the core members of product recall teams identified and trained in advance. It may be necessary to have one team at a corporate level to direct overall recall activities, and individual teams focused on specific aspects of product recall at the sales/marketing, distribution, manufacturing and communications levels. Plans and procedures should be developed and refined through training that should include simulating a recall.
4. Have back-ups for critical people and recall systems. Assume that some key personnel will not be available when you need them. Assume that the computer system where you maintain your stakeholder contact lists has crashed. Assume other similar worst-case scenarios and make back-up plans accordingly.
5. Have contact lists for all stakeholders set up on automated notification systems. This is particularly important for key retailers and distributors of your products. You can't rely on the media alone to reach them.
6. Consider the use of virtual incident management. There are a number of Internet-centered systems that allow recall team members to exchange real-time information, access current communications documents, and keep team leaders updated when the team is geographically scattered.
7. Make recall-related decisions that are based on protecting your brand and reputation, not just on legal and financial risks. The infamous Bridgestone-Firestone recall started far too late because the company's leadership was considering risks other than the most important one -- the risk of losing public confidence in their product.
8. Communicate internally as well as externally. Remember that every employee is a public relations representative and crisis manager for your organization, whether you want them to be or not. You must empower them with comprehensive messages about the recall suitable for their use with family, friends and neighbors. The worst possible scenario is for them to learn of the recall from external sources before they hear about it from you.
9. Don't wait for the FDA, USDA or other regulatory agencies to order something be done. While every regulatory agency that can get involved in a product recall has its own procedures, they can often delay the overall process -- a delay which, in a worst-case scenario, can lead to consumer injuries or deaths. In that event, the court of public opinion will react very negatively to both your organization and the regulator -- but your company’s revenue and reputation will be the most impacted.  Take the initiative and keep the regulators informed, but do not let them set the timetable.
10. Focus special communications on highly disgruntled customers, retailers and distributors. In this Age of the Internet, a few angry people can make waves completely disproportionate to their numbers or to the injury suffered -- if any. The recall process should include an "Escalated Cases" team to focus on finding and resolving such complaints.