Three Tips for Conducting a Mock Recall in the New Era of Smarter Food Safety

Mock recalls, which have always been a valuable tool for companies committed to food safety, must continue to be conducted and augmented as needed to accommodate these new requirements. Here are some tips to ensure your company has what it takes to stay vigilant in the New Era.

1. Establish and Empower Your Mock Recall Team

Let’s face it--food recalls must be conducted with precision to prevent harm. There are number of collaborators who all need to be prepared to drop everything and focus on them with urgency. Mock recalls work best when teams are aligned on a specific procedure. Quality assurance professionals, data managers, communications teams, customer service representatives, and even legal counsel all need to be comfortable in their roles. Mock recalls help these collaborators prepare for the daunting task of identifying and removing product from inventory and the supply chain.

Empower your mock recall team by clearly communicating specific responsibilities during a recall. When selecting the product to be traced, envision all of the “where used” possibilities—for example, if it was used as an ingredient for another product—to ensure all the right players are involved for appropriate reconciliation of raw materials and packaging.

Ever since the U.S. Food and Drug Administration (FDA) introduced the New Era of Smarter Food Safety blueprint last summer, cold chain companies have become focused of how to digitize and modernize food traceability. Many food safety procedures will soon become more automated and transparent in order to quickly and efficiently protect consumers from foodborne illness outbreaks.

Manual and paper-based processes simply don’t support the agility needed in today’s supply chain, not just in the context of the New Era, but also as pandemic-weary consumers continue to demand store-bought foods while social distancing. Both phenomena signify a critical turning point in food safety. Digital transformation plans are likely now in high gear in order to meet new requirements. Companies will be required to share more data than ever before with external partners in electronic formats.

In a mock recall, a company may name a QA or supply chain manager as a designated “initiator,” and an “approver,” whose responsibility it is to verify the information provided by the initiator. The initiator communicates information about the recalled product, such as instructions, reimbursement, supplier contacts, and other relevant information. GS1 US offers a standardized form created by food industry stakeholders that can be used for this called Rapid Recall Express. The approver ensures that what the initiator reported is appropriate and correct.

In a real recall, these professionals would select trading partners that should be alerted. 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. Overall, the team should be crystal clear on when to notify external partners and when to notify the general public.

2. Go Digital

One of the core elements of the New Era of Smarter Food Safety blueprint is to focus on Tech-Enabled Traceability, and the draft Food Safety and Modernization Act (FSMA) section 204 traceability rule emphasizes electronic record keeping. By maintaining electronic records, instead of paper-based systems, the speed and flow of data between trading partners can be vastly improved and the impact of a recall can be effectively minimized. Additionally, the New Era places greater emphasis on preventing recalls before they start, encouraging the use of predictive analytics and emerging technology, such as artificial intelligence and machine learning, to understand the specific patterns that lead to contamination.

What this focus on technology tells us is that it’s imperative—it’s no longer nice to have—that all relevant traceability data is collected at each stop in the supply chain. This data will fuel the technology solutions that make it easier to see where a product has been and where it is going. With today’s innovative technology solutions, a mock recall can be conducted in as little as 30 minutes if the proper attention is paid to data collection, data structure, and generally setting systems up for success.

3. Standardize Your Data

Most traceability systems in use today are built upon a foundation of global GS1 Standards to help identify products and product ingredients with precision, as well as provide a uniform way for capturing and sharing information about the products with external partners.

Using GS1 identification numbers, such as the GS1 Global Trade Item Number (GTIN), companies can track trade items and share supplementary information, i.e., expiration date, serial number, batch/lot number, to facilitate the communication of product-specific information wherever a barcode is scanned. These standards will also play a key role in how companies meet anticipated FDA traceability requirements that mandate the recording of Key Data Elements (KDEs) which includes location identifiers as well as the unique identification of products and raw materials, and Critical Tracking Events (CTEs) which includes gathering data for certain foods about any kind of transformation of a product or how it has changed possession along the supply chain.

Imagine a well-known ready-to-eat salad brand discovers its products have been contaminated with Listeria during a routine test. The company would be able to determine the exact ingredient affected using unique product identification and a traceability solution based on GS1 Standards. Specifically, the recall team could trace the products using Produce Traceability Initiative (PTI) labels, which are case labels with GS1-128 barcodes encoded with the item’s GTIN and lot number where it was harvested. Because the company has supply chain visibility based on standards and they conduct mock recalls regularly to stay prepared for these situations, they would be able to communicate publicly the exact pack dates, the states and retailers that the product was distributed to and the specific UPCs affected.

Ultimately, this year is placing a huge spotlight on traceability, with New Era plans being put into action, coupled with a continuing focus on food safety and transparency from consumers. Mock recalls confirm your company’s ability to trace products throughout the supply chain with speed and accuracy, and they can be a critical tool for evolving your food safety plan to meet new requirements.