On July 26, 2013, FDA issued proposed regulations that would greatly strengthen the oversight of foods imported for U.S. consumers. Under the Foreign Supplier Verification Program (FSVP) regulations, importers would be required to perform certain risk-based activities to verify that food imported into the United States has been produced in a manner that provides the same level of public health protection as that required of domestic food producers. The FSVP regulations would implement section 301 of the FDA Food Safety Modernization Act (FSMA).
Good food producers are not in the business of being good at recalls.
They are in the business of being good at producing food that doesn’t need to be recalled.
The whole objective of establishing and effectively operating good manufacturing practices and a sound HACCP management system is to produce safe wholesome food.
In the UK the majority of recalls in recent times have been modest in size and precautionary in nature. The mislabelling of products with incorrect allergen declarations offer potential risk for the unaware allergic consumers. Products have been occasionally withdrawn for packaging risks with unwanted glass contamination or risks in bottles that may be exposed to unplanned pressure.
The expense of operating a good quality and food safety system supported by effective supplier management and monitoring can be modest when weighed against the potential costs of a large scale withdrawal.
The latest precautionary withdrawals in the USA of several products from a number of companies concerned about Listeria Monocytogenes contamination is beginning to move into nightmare proportions when a whole months output is now being recalled by one producer.
It is surely a great incentive to heighten internal hygiene performance levels and look more closely at food complaints reports. Is your food supply chain management system up to scratch? Can you react quickly if an ingredient supplier starts a recall? Will your track and trace system allow you to identify the batches at risk and the customers who took delivery? And who can you turn to now for a safe replacement ingredient?
Ultimately is that big Elephant in your board room a total lack of pre-planning and scenario experience for managing a major food recall before it happens?