3 replies to this topic

[Clemkonan]

I am hoping to solicit ideas and or best practices applicable to developing a recall strategy that allows the organization to manage recall rather than being at the mercy of the media. I am having difficulty rationalizing what is the best strategy to use where it is determined that a potential hazard exist and where sample collection and subsequent product analysis has not yet taken place. An example would be helpful, so here goes.

We receive a complaint implicating our product in an illness lets consider three (3) scenarios:

1) There are multiple complaints, no hospitalization is required no children involved.
2) There is one complaint and again no hospitalization and no children involved.
3) There is one complaint involving a young infant, no hospitalization involved.

The product is pasteurized milk, which is a RTE item but Listeria is not considered to be a threat (based on probability and occurrence) and there is evidence supporting normal functioning of the P.H.E in other words the sterilizer is not defective.


My problem is as follows:
Do I contact the regulatory authority, suspend distribution and concentrate on getting product and conducting an analysis? This delay could result in a loss of 2-4 days how do I justify not taking reasonable action to protect little “Jonnie" who consumed defective product 1 day after I held product at warehouse level only?

My leaning is to: contact the regulatory authority > stop distribution at warehouse level > stop store sales at retail - which will amount to destroying product since retail outlets will generally not hold product > issue a class 3 recall > proceed with product analysis > work with regulatory to finalize the recall class which may have to be elevated to Class 2 or Class 1.

In scenario one I have multiple so I would probably be supported. In scenario 2 I would probably get shot or worse. In scenario 3 it’s a cliff hanger, children, the elderly etc, this could be open season for the folks on the 6 pm news.

Clearly the decision is not mine, I am simply trying to anticipate the problem and make a responsible recommendation.

Has anyone gone through this exercise I would appreciate some of your wisdom.

Finally, I have gone through recalls where I waited 3-5 hours for the regulatory body to come back with a final decision and a recall class. My concern is that many companies inadvertently proceed like its the regulatory authority's recall, they are content to sit back and wait and see how it plays out. However, the notification never says “Regulatory ABC is recalling product X”, similarly the media never camps out on their door. Consequently, it it’s my recall I want to manage it so that my organization comes out credibility and brand image in tact.

Regards
Clemkonan

[Simon]

Hi Clemkonan, It will be quiet over the weekend. In the meantime if you've not already seen it here is a link to a previous discussion on product recalls.

Welcome to the forums.

Regards,
Simon

[Clemkonan]

Can we bump this post up so that we can generate a response?

Thanks

[Penard]

Hello clemkonan,

Very difficult and interesting question...Very easy to answer theorically, but in case of real issue, that's another question!!

In your country it's right you have to be very carefully because medias are very strong - and if you don't react in a good way your factory can be easily out...

First of all, you are in charge of quality, but you're not the boss. Such a decision must be taken by the boss; you give him all the information, your opinion about the problem. If you want to be sure not to have problems, send to him a letter or a mail - sometimes it's very important to have a written evidence you inform him. Anyway you must inform your bos, whatever the result is.

Concerning the 3 scenarios I give you my opinion, what I would do if I still were in charge of quality :

You have to test your products with the same batch numbers -all the criterias, or some suspected criterias compared to symptoms.

1) inspect all your critical points - cooking, detectors, refreshing...if your products were always ok with the temperature for example, ask the production if all the parameters, unexpected incidents occured...Sometimes that's just hazard, but you have to be careful. You have to assess your decision regarding replies and facts.

2) The consumer is always right. Nevertheless, to me it's not a problem. Everyone can be ill after eating something, but that's not a food poisoning. Try to know more about it - allergens..., to answer him the quicker you can - very important for the good name of your factory, but it's not necessary to be anxious.

3) More important than 2). Children are always more sensitive than adults, and one more time the consumer is ALWAYS right. But sometimes they have some strange behaviours. Try to know more about it, in oder to answer very quickly. Your decision will depend on replies - just an isolated case, or be careful, just the beginning? Your Haccp study and your risk analysis will be very very important to be well prepared and have the best reaction as soon as you have the right information concerning issues.

That's all for me, what else?

Best regards,

Emmanuel.