We hear from our Strategic Advisor Sterling Crew on the disturbing increase in food withdrawals and the preparatory actions food businesses can take to best manage a potential withdrawal.

We hear from our Strategic Advisor Sterling Crew on the disturbing increase in food withdrawals and the preparatory actions food businesses can take to best manage a potential withdrawal.

Our food in the United Kingdom is amongst the safest in the world. There are many examples of good practice in the food industry but unfortunately, we tend only to hear about things when they go badly wrong. In these instances, products have to be withdrawn from the shelf. As we have recently seen, even the most admired and best managed businesses and brands can be involved in food incidents and withdrawals. It has become critical for the Food Business Operator (FBO) to reduce the risk of a withdrawal or recall and mitigate any resulting damage. Having an effective withdrawal management system enables businesses to build capacity to safeguard food and enhance consumer confidence.

What exactly are withdrawals and recalls?

• A withdrawal is the process by which a product is removed from the site supply network. Except for product that is already in the possession of consumers.

• A recall is the process by which a product is removed from the supply network and consumers are advised to take appropriate action such as returning the food or destroying it.

Allergen alerts

The Food Standards Agency (FSA) has reported an increase in the level of food and allergy alerts in England, Wales and Northern Ireland for the year ending 31st of March 2019. Food alerts rose by 52% to total 73 and allergen alerts increased by 28% to reach 118. There is however no evidence to suggest our food is becoming less safe. It is more likely that the increase is because we are now better at identifying problems and reporting them. Many food retailers and regulators are understandably adopting the precautionary principle when it comes to food safety and are avoiding taking unnecessary risks, especially in relation to allergens where there have been a number of tragic deaths resulting in wide and extensive media coverage. This however is just the tip of the iceberg, as the majority withdrawals go unreported. I believe that advances in UK food best practice and improving standards has resulted in our food being safer to eat than ever before.

The increase in allergen alerts is still worrying. I remember when I worked in manufacturing and retailing. The major safety concern was with allergen labelling errors, caused by putting the right product in the wrong pack and vice versa. This is particularly dangerous if it results in an under declaration of a listed allergen. It is also important for food business to ensure that they have strong controls to avoid allergen cross contamination on their premises and strict segregation and cleaning practices must also be followed. Due to the nature of the safety risk presented by allergens and the threat to business some organisations are investing in separate segregated sites to absolutely minimise the risk of contamination and product recall.

The recall process and facts on food withdrawal

There is a legal obligation for a FBO to inform the competent authorities immediately of a food which may be injurious to health has been placed on the market and the need for that food to be withdrawn. Food businesses that initiate a food withdrawal or recall must also check that the information has been received by its customers and action has been taken to withdraw or recall the food. Each part of the supply chain must be able to quickly trace all of the food received and dispatched one step forward and one step back. The ability to trace food and food ingredients through the supply network has become business critical. The purpose of traceability is to assist in targeted and accurate withdrawals and to give information to regulators in the event of food safety problems.

The results of the latest FSA Consumer Attitudes Survey showed that 18% of respondents reported never checking for a food recall alerts, and 17% reported being aware of a food recall alert in the past 12 months. There has been no notable change since the previous survey 6 months ago. Of those aware of a food recall in the past 12 months, 29% noticed it in store, 27% had heard it on TV/radio and 21% through social media. On a positive note 94% reported the information being very/quite clear.

Don’t wait until you are in a crisis to develop a crisis plan.

Bad news travels quickly in today’s social media driven world, and business must be prepared to react quickly in a crisis. A business crisis management system is a structured method that can be adapted to food related emergencies. A crisis is any event that has or is perceived to have, the potential to significantly cause harm to an individual, or damage the reputation of an organisation impacting its financial position. In a crisis quick action needs to be taken to mitigate a threat. A trained incident management team needs to follow pre-prepared plans, but must also be prepared to manoeuvre according to the changing circumstances. Facts need to be gathered to support evidence-based decisions. Protocols to identify and contact internal and external stakeholders should be developed and the system should be regularly updated and stress tested a minimum of once a year, in light of major change. The crisis management system stress test should include a mock withdrawal exercise and food businesses should keep traceability 12 months plus records for pre-packed food and shelf life data.
The human behavioural element of any withdrawal program cannot be underestimated. Withdrawals by their very nature are rare events and many businesses may be fortunate and never experience one. When I worked in retailing I managed a large number of withdrawals, they were an unfortunate and regular occurrence, a consequence of having so many different products on the shelf. I became used to the process and we had strong tried and tested crisis management systems. What always struck me was how unprepared some suppliers were. Amongst a number of suppliers there was an optimistic bias, “It won’t happen to our organisation,” or an illusion of control, “We know what we are doing, nothing has gone wrong in the past.” There was also an attitudinal ambivalence “There are more important immediate matters to be attended to.” This behaviour meant food retailers were often unprepared for the withdrawal and had therefore not invested adequately in crisis management.

Failures can give an organisation a chance to improve its approach to managing and mitigating risk. The Chinese use two brushstrokes to write the word “crisis.” One brush stroke for danger; the other for opportunity. In a food crisis, be aware of the danger but also recognise the opportunity for learning lessons and continuous improvement.

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