With pending Food Safety and Modernization Act (FSMA) traceability regulations on the horizon, it is more important than ever to have a mock recall process in place.
Mock recalls are routine exercises conducted by manufacturers, processors, distributors and other various trading partners in the supply chain to assess their recall procedures and responsiveness. Often described as the most valuable practice a company hopes to never have to actually use, mock recalls keep businesses prepared for an emergency event that could cost them time, money and their reputation.
While all recalls—in practice and in reality—are different and involve many variables, there are a few common steps that refrigerated and frozen food processors can keep in mind as they formulate their own mock recall plans.
Designate your recall team. Make it clear who will be responsible for each task in the process and develop a communication plan. For example, Rapid Recall Exchange (RRE), an online subscription service offered by GS1 US, Lawrenceville, N.J., provides a method for suppliers to communicate to retailers 24/7, alerting them that there is a product recall or market withdrawal event. When using RRE, a company will be asked to designate an “initiator,” a professional usually in a quality assurance role or a member of the customer supply chain team who is trained and familiar with the RRE tool and an “approver,” another professional whose responsibility it is to verify the information provided by the initiator. These roles will be important components in the notification of the recall to trading partners, should one be necessary.
Pick a random product on a random day. This product will become the subject of your exercise. This helps ensure a fast-acting process that is closer to reality. Often, similar to a fire drill, some companies will not even alert their team to the fact that the mock recall is just an exercise until after it has occurred. When selecting the product, envision how the product will be traced not only to the retailer, but also its “where used” possibilities—for example, if it was used as an ingredient for another product—to ensure the reconciliation of raw materials and packaging. The initiator inputs whatever information is available at that time into the RRE and adds to it as soon as more information becomes known.
Track the products using traceability procedures. Imagine you have become alerted to the quality of ice cream you received from a new supplier. With standardized traceability procedures already in place, it is easy to follow the path of the products through critical tracking events—those instances where product is moved between premises, is transformed or is otherwise determined to be a point where data capture is necessary to trace a product. The GS1 System of Standards enables companies to uniquely identify products in the supply chain to achieve supply chain visibility and efficiency. Using GS1 identification numbers, such as the GS1 Global Trade Item Number (GTIN), companies identify trade items as well as supplementary information, i.e., expiration date, serial number, batch/lot number, to facilitate the communication of product-specific information wherever a barcode is scanned. During the hypothetical mock recall of the ice cream, the processor can identify which pallets, cases and units were affected and where they are in the supply chain.
Reconcile the affected product with current inventory. Using standards, the team can also account for what is still left in the inventory and determine a reconciliation percentage, which helps to measure the success of the mock recall. With the goal of establishing 100% reconciliation (plus or minus a percentage), the recalled product is measured against the production record to account for all product that may have been affected—whether it has left the facility or remains under the manufacturer or processor’s roof.
Use Rapid Recall Exchange to simulate the communication of the event. RRE users can take advantage of the “test environment” to stage a mock recall (as opposed to the “production environment,” which is reserved for actual recalls or withdrawals). The designated initiator enters in the necessary information about the recalled product, such as instructions, reimbursement, supplier contacts and other relevant information and attaches any related documents. This information is then sent to the company’s designated approver, who ensures that what the initiator reported is appropriate and correct. In a real recall, RRE allows the company to select trading partners that should be alerted. This practice may be particularly useful for the refrigerated and frozen food industry, which often requires a large distributor network. Depending on the type of product being distributed, many processors may have to alert several more parties in the event of a recall, including outsourced transportation partners who play a role in the interception of products at various stopping points.
Critique your mock recall results. Record the results of the mock recall and use them as a benchmark to track your company’s performance. After each exercise, it is important to evaluate the need for a change in procedure or perhaps to consider implementing new technology to streamline the recall process.
While companies might vary in their approach to mock recalls, keep in mind the following best practices to ensure you are pressure testing yourself in the most productive way possible:
Frequency. It is highly recommended to conduct recalls quarterly, but some companies test less frequently (twice a year) or more frequently (monthly), depending on their specific products and manpower. This can be adjusted as mock recall reconciliation numbers improve or fail. So, if a company is continually slipping well under its goal of 100%, mock recalls can be increased to monthly until the percentage improves.
Duration. With today’s technology, a mock recall can be conducted in as little as 30 minutes or as much as 24 hours. With FSMA regulations looming that require accurate documentation of traceability procedures, it is beneficial for all trading partners to migrate to electronic records to ensure quality data and streamlined communications avenues are readily available.
Objective. It is important to have a clearly defined goal and objective for the mock recall being conducted, as these exercises can be done to validate specific processes and confirm suspected weaknesses. Mock recalls confirm that your company can trace products throughout the supply chain and determine whether or not your communications plan is efficient. Ultimately, mock recalls are about mitigating risk and measuring your ability to react to an emergency event with as much precision as possible.