Despite an increased emphasis on prevention — particularly with the rollout of the Food Safety and Modernization Act — recalls are a daily part of doing business in the food industry.
By the end of 2017, hundreds of items will have been identified, tagged and removed from the food chain as part of an intricate, well-honed system meant to limit the effects of contaminated food on consumers and businesses.
For retailers, recalls present a particularly tricky proposition. Although they are typically not the ones at fault for product contamination, grocers are tasked with a multitude of responsibilities, from pulling product to reassuring consumers to setting the record straight with news media.
“The retailers down to the store managers take these matters personally in thinking about the customer,” Gail Prince, president of Sage Food Safety Consultants and former director of corporate regulatory affairs for Kroger, told Food Dive.
Considering what’s at stake, it’s worth looking at what, exactly, happens at the retail level during a food recall.
Although procedures vary from retailer to retailer, there are certain steps mandated by federal law and consistent across the industry during a recall.
For starters, most recalls are issued voluntarily by suppliers. The Food and Drug Administration and, to a more limited extent, the U.S. Department of Agriculture's Food Safety Inspection Service can force recalls in the event of a pronounced public health risk.
Once a company has deemed a product to pose a risk to consumers, it notifies the appropriate regulatory agency. The FDA, for one, requires that whoever is responsible for a product’s production — typically the manufacturer — must notify the agency within 24 hours if that product is deemed to pose a public health risk.
From there, the company contacts the retail buyer and begins discussing how to initiate a recall.
“It starts with that business relationship between the buyer with the retailer, and then the communication expands from there quickly to the food quality assurance professional within the retail company,” Hilary Thesmar, vice president of food safety programs with the Food Marketing Institute, told Food Dive. “It is a well-oiled machine.”
Manufacturers, she noted, don’t go through recalls very often. They will often lean on the retailer’s expertise.
“Manufacturers might only have a recall once every couple of years, maybe once a decade,” Thesmar said. “For them, a recall is a crisis. But for a retailer, a recall is something where they know exactly what to do.”
“Manufacturers might only have a recall once every couple of years, maybe once a decade. For them, a recall is a crisis. But for a retailer, a recall is something where they know exactly what to do.”
Vice president of food safety programs, Food Marketing Institute
In some cases, the problem may be a quality issue rather than public safety issue, and can be dealt with internally, noted Prince. But if a recall is determined to be the best option, the retailer must then go about collecting information about the contaminated product, including the lot numbers, UPCs, distribution and shipping information. This task usually falls to the food safety team or the public affairs department — or both. Once workers have all this information, they then issue an internal recall notice that goes out to affected stores.
According to Prince, who is known in the industry as “the dean of food recalls," a recall notice helps workers identify and handle contaminated products. One of the most crucial pieces of information, he said, are the UPC codes that help track down products.
“UPC numbers are very vital in recalls so you can follow the distribution as well as who purchased the product,” said Prince.
Once stores receive the recall notices from the central office, employees then begin pulling products from shelves — a process that takes two hours or less, according to Thesmar. Workers also identify products in backrooms, on trucks and other locations throughout the supply chain.
Product containers are typically marked in some way that indicates they are recalled and should not be distributed to store shelves. At the same time, many retailers will also block a recalled product’s UPC code so that, in case that product is still out in circulation, it won’t scan at the register.
“It’s very important for retailers to provide information about that recall all the way down to the store cashier, who needs to know not to override those blocked UPC scans,” said Thesmar.
Ideally, a retailer will recall products before they hit store shelves. If some of those products have made their way out into the store and been purchased, however, grocers will go about notifying shoppers. This can happen any number of ways, and depends on store policies and the risk to the public.
For Class 1 recalls, which indicate a serious health threat, retailers will often post signs at registers, on store bulletin boards and at the point of purchase explaining why the recall is happening and telling consumers to bring in recalled products for a full refund. Retailers will also post notices on their websites, and frequently use loyalty card data to identify and contact customers who purchased a recalled item.
Paul Bernish, a communications consultant with Bernish Communications and former head of corporate public relations at Kroger, noted that social media has become the most effective way many retailers can quickly reach consumers. Facebook and Twitter can spread the word of a recall as users share and retweet news. This is a big change from the ‘80s and ‘90s, he said, when retailers relied on newspapers and television stations to inform shoppers.
Still, he believes the need to be forthcoming with consumers hasn’t changed.
“The standard was that we would be as forthcoming as we could be, in large part because we wanted to avoid consumers becoming unnecessarily alarmed or anxious about the quality and safety of the food,” Bernish told Food Dive.
Despite its speed and effectiveness, social media does present unique challenges, according to Bernish. With no “editorial gatekeeper,” users can easily spread false information. If a user believes he or she is a victim of contaminated food and tweets or posts about it, that post could go viral and create a panic that the retailer must fight to contain.
The potential for things getting out of control is why many retailers employ social media specialists, Bernish noted.
“Companies have had to adjust their internal practices to make sure they’re moving quickly to deal with the situation, and at the same time to be out in the social media sphere countering rumors, and being clearly identified while doing so,” he said.
“Companies have had to adjust their internal practices to make sure they’re moving quickly to deal with the situation, and at the same time to be out in the social media sphere countering rumors, and being clearly identified while doing so.”
Consultant and former head of corporate public relations at Kroger
Currently, there are only two recall notifications required by federal law: a posting on the FDA’s recall website, and a press release issued by the company that's conducting the recall. Consumer advocates argue that this doesn’t adequately inform consumers, and creates an uneven system of recall notifications that vary from retailer to retailer. Last year, The Center for Science in the Public Interest surveyed 32 of America’s top grocery chains to see how they notify consumers in the event of a recall. The organization found that, while most retailers do post recall notices in their stores, the placement of these notices varies. One chain, the organization found, didn’t post notices at all.
“We found them to be very uneven in terms of where they were posting these notices and what they were posting,” Jim O’Hara director of health promotion policy at the Center for Science in the Public Interest, told Food Dive.
Under FSMA, retailers with 15 or more stores must post recall notices in conspicuous locations inside their stores for 14 days. The FDA, however, has yet to issue final guidelines on that provision.
According to Thesmar, standardizing recall notices this way would take away retailers’ flexibility to notify their customers in the ways they know best. It would also treat all recall levels the same, and wouldn’t help customers differentiate between urgent and non-urgent recalls.
“We’re concerned with standardization that everything would just blend into the background, that there’d be fatigue with all the recall notifications,” said Thesmar. “Your Class One recall would look the same thing as one that’s mainly in the supply chain and has been taken care of.”
O’Hara said standardizing notices in stores would be a good first step to achieving consistency across the industry with notifications. He believes there’s a bigger problem, though: The FDA’s refusal to name retailers and manufacturers in their recall notices. The agency says it’s following a law that prevents it from revealing trade secrets — an interpretation that CSPI and many other organizations strongly disagree with.
“The FDA is frankly putting commercial interests above public health interests,” said O’Hara. “If the FDA would publish that information, then some of these other issues would resolve themselves."
Focusing on prevention
After a retailer has carried out a recall, the store needs to write a root cause analysis and file it with the appropriate regulatory agencies, Prince said. The analysis examines what happened, how the retailer dealt with the issue, and prevention steps for the future.
Preventing food recalls from happening in the first place, sources said, is a top priority for the food industry. Manufacturers as well as regulatory agencies are doing more preliminary testing to identify contamination before products make their way through the supply chain. This testing, said Prince, has become so advanced that companies can pinpoint specific batches and ingredients. This results in more surgical recalls that can save time and money.
“Detection has gotten much faster and is pinpointed to a level now where scientists are able to identify an ingredient in a product,” he said. “Before, they were always just looking at the product level. Now, they can go much deeper.”
Two forces have spurred this increased focus on prevention, Prince noted. One was a rash of high-profile outbreaks that occurred a decade ago, including a 2006 outbreak of E. coli linked to Dole spinach and the massive salmonella outbreak in late 2008 linked to Peanut Corporation of America. The other is FSMA.
Although most of the regulatory burden under FSMA falls to manufacturers, retailers still face compliance in several key areas. This May is the deadline for implementing verification procedures for foreign suppliers.
Retailers also face FSMA compliance with their distribution centers, which fall under FDA oversight, and with any private label manufacturing facilities they might own
“What they want is a demonstration that the entire food industry from the manufacturer to the retailer has acted responsibly to get the problem resolved as quickly as possible."
Consultant and former head of corporate public relations at Kroger
“[Retailers] just have to be a little more buttoned up,” said Thesmar. “They have to make sure they’re compliant, that all their paperwork is compliant with FSMA. They have to make sure that all of the appropriate people in that facility are trained, and that the training is well documented.”
Beyond this, grocers are focused on implementing food safety best practices in high-growth areas like fresh foods, private label and local products. Each of these categories presents unique challenges, Prince said. There’s one step that can be applied in all cases, and could go a long way towards preventing a recall.
“Three words: Know your supplier,” he said. “You have to actually get out and look at that supplier to make sure they’re knowledgeable, and look at some of their key programs to make sure the proper safety measures are in place.”
But because recalls will continue to be necessary in the future, the retailer's plan to deal with them is important to consumers.
“What they want is a demonstration that the entire food industry from the manufacturer to the retailer has acted responsibly to get the problem resolved as quickly as possible,” said Bernish.