Recent food dye scares have again emphasised how vital it is for food manufacturers to have the right procedures in place to deal with contamination issues and product recalls. But with some big questions having been raised about the value of the certificates of assurance, one top expert is urging food manufacturers to ensure they have procedures in place at the beginning of the chain.
Carrying out your own testing, and on an extended number of ingredients as soon as you have cause for concern, as well as simultaneous third-party external tests, is now essential, according to Katherine Cahill, global MD of risk consultancy Marsh’s product recall and prevention services arm.
General Mills, for instance, only found Para Red in its Old El Paso kits when its suppliers extended testing to look for other banned dyes following Sudan 1.
Bart Spices had never heard of Para Red until it was detected in its ground paprika in April.
Both companies handled the resulting crisis well. But what lessons can be gleaned from their experiences, and from the wider issues of Sudan 1 and Para Red?
For starters, says Cahill, every company should have the right sort of protocols in place to avoid being caught unprepared. Initially, a product recall plan must be formulated. Companies need to put together a recall task force, decide which staff will be part of it and who needs training. Each person’s job must be defined and the company must understand how it plans to handle the media and negotiations with authorities.
If a contamination is discovered, Cahill says companies must first understand how big a problem they have on their hands. And that means knowing how the complaint has come in: “Have you received one phone call or 10? It’s essential to define what you know.”
It is also critical to get hold of the contaminated product and run your own and third-party testing simultaneously to ensure all bases are covered, she says. Companies must also look at the regulatory reporting requirements as early as possible. “These vary from country to country,” warns Cahill. “In the US, it’s just a few hours whereas companies in the UK are given a reasonable period of time to report the problem to the FSA.”
While there’s no exact timing given in the UK to file a report with the regulators, under the Food Act companies are required to immediately notify the FSA and their local authorities of a problem.
“But look at what it means to your company and how you can handle it in a way that benefits you in some way. I’d always push for voluntary recall over involuntary, as it gives you a chance to maintain your brand integrity.”
Referring to the recent Sudan 1 cases, Cahill says it does not matter whether or not low levels of the dye pose a real health risk. “If you have an agent you know can cause cancer, and regulations say it shouldn’t be in food, then it doesn’t matter how little you find,” she says.
As soon as the report is filed, companies must tell their insurer. “Once that is done, companies must work out how to put a fence around the problem,” says Cahill. “They must define how far the incident has gone, how much has been affected and whether it was accidental or not.”
Traceability is vital in all of this, she says. “We need to know where it’s come from but also where the product has gone after your company and beyond the shops.”
Having gone through these steps, Cahill says a company must look at how to end the product recall. “How do you decide when everything’s been done and how you can put an end to it?”
It’s important to negotiate with regulators at every point, she adds. “If you can show how quickly you identified the problem, how quickly you reported it and how quickly you then destroyed the product, it all works in your favour. And, importantly, this shows you’re a good corporate citizen.”
“If you can show how quickly you identified the problem, how quickly you then destroyed the product and how quickly you reported it, it all works in your favour”