Trouble at t'mill
If a recall occurs at a feed mill, there are a number of things that need to
happen. All of them require communication and planning.
The following slides outline the series of steps taken in a recent feed
product recall for poultry products from the point when an issue was
identified. Issues can be identified by your customer, retailer or internally
by your own team.
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Additional information can be found at the MPI website
• http://www.mpi.govt.nz
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This presentation also includes some talking points for you to consider
when dealing with or planning your recall training and preparedness.
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This presentation is not considered to be a complete guide and you
should always seek further information.
Product Recall or Product Withdrawal?
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Product Recall
• A recall involves removing unsafe product from the distribution chain
extending through to product already sold to consumers, and hence
the public needs to be informed. Notification to statutory authorities
and media is required.
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Product Withdrawal
• A withdrawal stops at the point at which food is sold to consumers –
only suppliers and retailers will be involved.
• Withdrawals do not require notification to statutory authorities or
media.
Step 1: Assessment of the Issue and
Potential Risk
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A Recall Management Team was assembled, made up of the
management team and key functional members (3 meetings over 3
consecutive days)
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Reviewed all data that was identified in the issue
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Consulted with suppliers and experts on questions raised at meeting
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To gain a better understanding of risk and issue
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Identified all products affected including batch codes, sales volumes and
distribution
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Based on all facts known, a decision was made to notify MPI about the
issue and to put all poultry bagged products on hold
Step 2: Notified MPI
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Contacted MPI verbally to identify the issue at hand
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MPI Key Outcomes
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This was followed up with formal notification
Received a formal reply next day
Held 4 meetings over 4 consecutive days via phone conference with MPI
MPI completed its preliminary risk assessment and instructed the company to
proceed with the public recall of the poultry bagged lines
MPI did not require a health advisory within the public recall notice
MPI advised the following government offices:
• Prime Minister’s Department
• Ministry of Food Safety
• Ministry of Health
Step 3: Preparing to Recall
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Product specifics
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Communications
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Identified and confirmed what products fell within the recall period and what
the batch codes were
Identified what product we still had in our possession
Identified what products we had to recall – didn’t want to recall products that
we had and weren't out at store or customer level.
Enlisted a PR’s expertise to “wordsmith”
Created communications
• Letter to retailer
• Letter to customer
• Customer enquiry form
• Recall media statement
• Recall flyer for on shelf
• Customer Q&A and second-tier question process
• Recall notice as per MPI requirements
Recall Notice
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Recall notice requirements:
• List company name and address
• Identify the products in the most
consumer-friendly way
• Be a set size
• Detail the exact problem with the
product
• Not have any promotional info.
included
• To be published in all regional
newspapers
• Posted on website
• Posted on MPI recall website
• Approved by MPI
Step 4: Communication Plan
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Step 5: Commence Recall
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Recall communications
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Product Return Process
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Notifications went to all retailers
Recall notice was published in required newspapers
Communication on how to get product back sent to retailers and head offices
Key stakeholders were also communicated to, including suppliers
Communications went to all internal staff so they were aware of what was
occurring.
A process was created to get all product recalled back to our distribution
centre.
Step 5: Retailer Product Recall Process
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Pick-up of “Store Inventory Stocks”
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Customers Returning Product
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From the Fax Recall Sheets we have compiled a full list of all stocks in stores
Pick up of the store product will occur over Friday 24th June and Monday 27th
June
All stocks received back into our distribution centres will be reconciled against
the Fax Recall Sheets received from each store
Arrange for credits to be processed on all store stocks that are received in line
with the Fax Recall Sheets – credits will be processed at current wholesale
pricing
Provide affected customers with feed vouchers that can be used for any of our
bagged feed product brands
Only provide replacement feed vouchers to customers that bring in full or part
full bags of affected feed. We are unable to provide any vouchers for
replacement product on the return of empty bags as this is a product recall
process
When we receive the fax copy of the Customer Return Form, contact each
store to arrange for pick up of returned product
Step 5: Retailer Product Recall Process
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Ordering New Replacement Stocks
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Separation of new stock going out and recalled stock coming in was
critical
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June product fully tested and available for distribution by late next week
We will begin accepting orders for replacement product from Monday 27th
June
Product needed to be identified clearly
Product not even in the recall came back
Step 6: Handling Recalled Product
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Full Pallet-Bagged Product
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Opened/Partial-Bagged Product
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Opened (partial) bags – safely disposed of
Unopened (full) bags – dairy rework
Storage and handling of the product returned
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Full pallet-bagged products tested and reworked into production subject to
testing
Subject to MPI approval of process
Isolation from other fresh stock
Management of mite and other infestation risks
Product outside the recall – old stock
Step 7: Effectiveness of Recall
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Percentage of recall received back:
Unsold Retailer Product
Region
South Island
North Island
Total
Retailer Claims
(Bags)
2,450
6,890
9,340
Retailer Claims
(MT)
61
173
234
Collected (MT)
Collected (%)
63
166
229
>100%
96%
98%
Collected (MT)
Collected (%)
2
7
9
66%
63%
64%
Customer Claims
Region
South Island
North Island
Total
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Customer Claims
(Bags)
125
428
553
Claimed (MT)
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Step 7: Effectiveness of Recall
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Monitored calls to customer services and nature of call:
Date(s)
Total
Calls
Store
Enquiry
End User
Enquiry
*Elevated
%
Comfortable
%
Concerned
June 24
64
15
49
8
80%
20%
June 25/26
18
0
18
2
80%
20%
June 27
June 28
June 29
June 30
July 1
July 4
July 5
July 6
52
46
32
37
44
21
12
8
10
19
11
12
10
6
3
3
42
27
21
25
34
15
9
5
4
1
1
2
6
1
0
3
80%
78%
90%
70%
80%
90%
100%
63%
20%
22%
10%
30%
20%
10%
0%
37%
Step 8: Root Cause Analysis
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Complete root cause investigation
Meeting with MPI – Audit
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Review of recall documentation and processes to date
Outcome: MPI comfortable with actions and recall processes
Ongoing correspondence will occur between both parties as further
investigation is conducted
Currently using a hold and release programme for poultry products
This monitoring and communication is still ongoing
What we learned / What we recommend
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Recall Management Team
Dealing with MPI
Dealing with Retailers
Quality Control
Recall Management Team
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Recommend establishing formal Recall Response Team
• Leader with clear accountability
• Clear roles and responsibilities
• Have the ability to take actions away and execute with greater team
• Have one key contact to liaise with MPI
• Small and manageable expands to large and executable
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Must convene early
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As soon as there is any indication of an incident that may escalate
Before Police, Health or any other external party become involved
Must think through the consequences of any actions and ensure process
is objective and not emotive
Practice / Mock Recalls on regular basis to ensure participants are aware
of process and barriers to executing correctly
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Dealing with MPI
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Give MPI the information it asks for and no more
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MPI wants specifics and not all the data
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Give MPI solutions based on industry knowledge and experience or MPI
will have to go away and find solutions
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If the issue spans two different areas, MPI will need to consult other MPI
departments
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The responsibility for managing any risks associated within the recall is
ours, not MPI’s. MPI will guide but not take ownership
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MPI works office hours
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MPI will act if you don't
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A relationship with MPI helps in times such as recalls
Dealing with Retailers
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Confusion at store level will occur if communication isn't clear and the
recall process isn't simple and workable:
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Don’t overpromise to the stores
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Product removal from stores’ timelines – if timelines are committed to, make
sure you stick to them
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Approx. 40% of product was returned without the required identification
information
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Follow-up communication with retail stores (clarify process)
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Product continued to be sold in some cases
Some retailers were not giving product back to transport companies
We received product back that was not in the recall
Don’t assume retailers’ head offices have sent the stores all the info. and
correct instructions
Communication
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Create a Communication Plan
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Internal people need to be told the same as external
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Make it as simple as possible to follow
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Ensure that communication has been passed on every level required to
execute the recall – both external and internal
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Subject to legal privilege
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Who, when, how, and what
Emails that are distributed internally may be discoverable in an external
investigation
Documents recording investigation findings should be kept confidential, where
possible marked: ‘Subject to legal professional privilege’
and communicated directly to the lawyer for the purpose of obtaining advice.
Quality Control
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Traceability is critical – on raws and finished product
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Make haste slowly!
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Knowing what to do is 75% of a recall
Identify where your process breaks down and could cost you more
MPI has recall plan templates
Validation of processes.
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You need to act fast but make sure you have all the facts first
Mock Recalls – Practice makes perfect
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The more traceable your product is, the less you will have to recall
Batch coding needs to be clear and easily readable
Critical control points – confirm they do what they are meant to
Flushes and safe feed matrix – confirm they result in safe process
Testing programmes – confirm they capture what is needed