No Dirty Secrets

by Jennifer Barnett Fox
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Each food product recall is unique, but all contain missteps of food safety basics. In light of this, food manufacturers might do well to heed the advice of Sir Winston Churchill who said, “Those that fail to learn from history are doomed to repeat it.” Rather than creating an atmosphere of secrecy surrounding recalls, the industry could benefit from an open discussion regarding recall successes, thus promoting a learning opportunity for the entire industry.

For now, the idea of openness regarding recalls is met with suspicion, but basic food safety steps such as practicing mock recalls and following Hazard Analysis Critical Control Point (HACCP) programs, good manufacturing processes (GMPs), standard operating procedures as well as knowing your supply chain and third-party assistance remain the first line of defense.

Despite these protections and good intentions, the recent glut of recalls has prompted consumers to ask if the na-tion’s food supply was safer in the past. Thankfully, the answer is an unequivocal “no,” but the industry’s intense com-mitment to produce safe food has resulted in the discovery of potential issues that might have gone unchecked in the past, according to Gale Prince, president, Sage Food Safety Consultants, Cincinnati, OH.

In both the recent peanut paste and egg recalls, the involved companies produced only 2% of the commodity, accord-ing to Mr. Prince. Yet, as recent events proved, 2% can still create a negative impact on the industry. “When people let down their guard and become complacent by not paying attention to basic things such as HACCP and GMPs, then people could become ill,” Mr. Prince said.

CREATE A PLAN.

Companies walk a tightrope between producing safe food and relying upon consumers to do their part through responsible preparation and cooking skills. Despite these measures, what happens if a recall does occur that implicates not just your company but also suppliers, distributors and, ultimately, end users? Does your company have a tested crisis management plan in place to get accurate information out at a moment’s notice to all that could have the product?

While each company creates its own policies regarding crisis management plans, many follow guidance from the Food and Drug Administration (FDA) and put in place a crisis management team that includes the c.e.o. and individu-als from operations, legal, HR, sales and marketing, QA, customer relations and often an outside PR agency that spe-cializes in such issues.

“Success comes with having the right people and being crystal clear on the objectives in this endeavor,” said Chris Scott, former president and c.o.o., Little Lady Foods, Elk Grove Village, IL. “Depending on the risk to the public, your No. 1 concern is to provide the best information to keep people safe. Everything else is secondary.”

NEWS TRAVELS FAST.

Today recall information becomes viral before the evening TV news airs or tomorrow’s news-paper hits the printer. In the event of a recall, it ultimately falls to manufacturers to inform its suppliers, distributors and end consumers on the status of contaminated product. Consumer trust is further damaged by manufacturers who refer recall inquiries to law firms who don’t return calls or by companies that blame consumers for incorrect prepara-tion skills. Those that rely on outdated crisis plans are guaranteed to incur consumer and media outrage that can be difficult to repair in the short-term and can damage the bottom line longterm. Recent media examples include Tiger Woods’ two-month silence on his affairs and BP’s reluctant apology two weeks after the Gulf oil spill.

In cases such as these, silence is not golden, and manufacturers that confront food safety issues honestly and head-on with transparency generally win the respect of consumers in the end, ultimately boosting consumer loyalty and salvag-ing the bottom line in the long run. Several years ago, Kinnikinnick Foods, Edmonton, AB, conducted a voluntary recall of donuts Upon discovering the labeling error, the company enacted its crisis recall program to inform its 45 distribu-tors and 7,000 stores of the mistake.

Within two days, Kinnikinnick also contacted all consumers who purchased the donuts by phone and offered re-funds. While only two of them asked for refunds, the company gained a loyal group of consumers. “We’ve worked hard to be known as a safe company, and I believe if you’re honest and show how you will rectify the situation, most will understand,” said Jerry Bigam, president, Kinnikinnick Foods.

Today the company boasts a more sophisticated crisis management plan, which includes a stringent commitment to keeping contaminants out of its dedicated gluten- and nut-free plants and an active communications component that includes social media. Each shipment of ingredients is tested upon reaching the facility, and the company is particularly selective in its supply chain partners. While many food safety problems won’t show up for days, gluten contamination is typically discovered by consumers within minutes to an hour after eating. “Celiacs will know if there’s a major issue that needs an immediate response,” Mr. Bigam said. “Other contaminants, unfortunately, take more time to notice.”

WHERE TO BEGIN?

So, what if you can’t directly pinpoint where the issue originated? That often happens when com-panies don’t have good recordkeeping, don’t know their supply chain or don’t have a solid crisis management plan in play.

RQA, Inc., a consulting firm comprised of food industry veterans and food safety professionals, supplies technical, crisis management and product retrieval expertise for companies in recall situations. When creating a crisis manage-ment plan, RQA encourages companies to identify a crisis team consisting of cross-functional representation who can collectively assess and implement the crisis plan when the need arises. Crisis team members include leadership from the following areas: food safety and quality, distribution and warehouse management, legal, consumer affairs and public relations, according to Melanie Neumann, Esq., vice-president crisis management and general counsel, RQA, Inc., Darien, IL.

“Effective crisis management is like a 3-legged stool — people, processes and systems are the legs that must support the seat, which is the crisis. Applying this analogy, companies must have a crisis team in place that is aware of their roles, a robust written crisis plan explaining applicable crisis procedures and reliable traceability and consumer com-plaint systems to uncover the depth of the issue,” she said.

Ms. Neumann stressed the importance of a robust traceability system and a strong investment in IT infrastructure. All ingredients and primary packaging deliveries and finished product production and distribution should be tracked by an electronic product management system. “Delays in a recall situation are often because of suboptimal traceability where companies lose visibility into what went into the product and/or where the product went in the supply chain,” Ms. Neumann said. “Take a critical look at your traceability capabilities and be confident that you can run required reports quickly and accurately.”

This is especially important because of FDA’s Reportable Food Registry’s 24-hour reporting requirement. Although the clock doesn’t start until the company has reason to believe a food rises to the level of a “reportable food,” sizable delays beyond 24 hours may be questioned by regulatory agencies, she cautioned.

Ms. Neumann recommended areas of additional support for implementing a strong crisis management strategy in the midst of a crisis. First, identify experts who can help conduct and understand a health hazard evaluation and under-stand the specific technical and regulatory risks associated with the cause of a recall. In cases where heavy media scru-tiny is likely, consider securing a PR firm experienced in handing food recalls. “It’s very important that the PR agency be experienced in food/beverage recalls because time is of the essence. You don’t have time to educate a PR firm on agency regulations and expectations, so select one with experience” she concluded.

TIME SENSITIVE.

In the event of a food recall or company crisis, time is one thing that you won’t have enough of. Ar-ment Dietrich, a Chicago, IL-based public relations agency, creates crisis management plans for companies built on education, communication and transparency. “The faster you get out in front of something from a crisis standpoint and the better communication you have, the easier it will be,” said Gini Dietrich, founder and c.e.o., Arment Dietrich. “Peo-ple want to hear I’m sorry for screwing up and how it’s going to be fixed.”

Arment Dietrich recommended that companies begin by assigning a point person such as a marketing or communi-cations person who will communicate directly with the public through a variety of mediums, if required. Before any problems surface, Ms. Dietrich suggested identifying potential crises and creating a written response plan for these situations in TV, print, Web and social media such as YouTube, Facebook and Twitter. A fire drill of these procedures should be performed every six months or more often if key personnel change. All information, along with a toll-free number, can be posted to a “dark” Web site that will be “lit” only in the event of a crisis. The site will again go dark when the need for such information has passed.

Ms. Dietrich stressed that the legal team and public relations components must be “on the same page” about neces-sary actions before a crisis occurs. She also recommended actively monitoring online through sites such as Google Alert to determine what’s going on with your brand and in the industry. Twendz is another reputation management tool that looks at the sentiments expressed about a brand or topic and measures the tweets on Twitter for positivity, neutrality or negativity.

“At first, this kind of situation can be embarrassing, but there will be nothing to talk about if you are upfront and tell your story,” Ms. Dietrich said. “If you don’t tell the story, you are leaving it up to others to tell it for you.”

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