The idea of being ‘recall ready’ has been around for years, but a news release from the FDA earlier this year has brought it to the forefront. The release, headlined FDA Urges Companies to be ’Recall Ready’ to Protect Public Health as Part of Final Guidance for Voluntary Recalls, speaks to well-known and well-worn guidelines for being ‘recall ready.’
It’s great that guidance of this kind is coming from the FDA. Being in the recall business, we see on a daily basis how vital it is for companies not only to take prompt action but also prepare ahead of time. The more we talk about this, the better.
However, it’s important that in talking about it, we also put guidance into action. Encouragement from the FDA is a great start. The industry also needs leadership for implementing the guidance. We aren’t the only ones thinking along these lines. In July 2021, STOP published the Collaborative Plan to Achieve Customer-Focused Recall Modernization to recommend “a strategic approach to modernize the entire recall system and enhance its overall effectiveness for the consumer.” We agree that there’s a need for process changes in the way food recalls are conducted.
As we assist our clients with recalls, we repeatedly hear – regardless of whether it’s from suppliers, distributors, or retailers – that companies are overwhelmed by how fragmented the recall process is. We saw this fragmentation at play with the recent infant formula recall. Incomplete information led to confusion, which slowed the action to remove affected products, and ultimately resulted in more risk to consumers.
Good recall processes certainly exist. Many individual companies have developed best-in-class processes that serve them well. In fact, most companies we interact with consider themselves ‘recall ready.’ Yet the infant formula recall is not an anomaly. Where’s the disconnect? The problem is that individual ‘recall readiness’ doesn’t translate into a solution that benefits the entire supply chain. There is no consistency, which results in recalls that are inefficient at best, and a crisis at worst.
We have been exploring the concept of a Recall Ready Community where everyone involved in a recall works in sync. The idea of community suggests that we focus our efforts on what is good for the whole, not just the individual. This approach shifts us from the current state of fragmentation to an interconnected supply chain that knits together the process in a way that serves everyone.
A Recall Ready Community is characterized by clear communication, trust, and speed. Built on a shared commitment to a standardized and modernized recall process at every point in the supply chain, it would uphold process standards that improve the recall process for manufacturers, distributors, and retailers – both individually and collectively. Examples of process standards include simple data input platforms, fast communication, and automated information dissemination to the regulator, the retailer, and the consumer.
There also must be a preparatory integration step. Practice is required to ensure recall information flows quickly and correctly to others who need to take action. In mock recalls today, the communication piece of the plan is not practiced, only the product traceability. We need to effectively modernize mock recalls to exercise the process completely.
The idea of a Recall Ready Community has already struck a chord with top leadership at key associations such as the American Frozen Food Institute and the National Grocers Association, ROFDA, National Animal Supplement Council and businesses across the supply chain. What we need most right now are thought leaders, industry experts, and representatives from all sectors of the supply chain to come together in creative collaboration. A community approach can build a community solution that will truly ensure we are ‘recall ready.’
This article was first published on April 6, 2022 as a guest contribution to Partner Outlooks from The Acheson Group.
