"What happened to Topps was a shame, but this is an industry wide problem and it's just a matter of waiting to see who is going to be next. It won't change until we get better safety standards all the way back to the farm." Guy Giordano, President of Vincent Giordano Corp Reduce Risk – Not everyone in the industry needs the multi-million dollar pasteurization system the Vincent Giordano Corp has invested in, but everyone can benefit by taking steps to reduce the risk of foodborn illness and contamination. As we discussed in Article 119 there are a number of methods to keep bacteria at bay. One of the most important is simple hygiene and thorough sanitization. If you're looking for a refresher on the temperatures and chemicals recommended for sanitization take a look at the resources provided by Penn State. Segment Exposure – Topps has issued recalls on over nearly 21 million pounds of ground beef, nearly an entire year worth of patty production. While details on what conditions caused this widespread contamination have not yet been released, you can take steps to prevent a similar occurrence. Review your workflow, concentrate on finding an eliminating any chances of cross contamination. Common sense items like knives, hooks, cutting blocks, aprons and machinery are addressed frequently, but when was the last time you cleaned the stocker's box cutter, washed down the pallet jack controls, tried to sanitize your salesperson's neck-tie, or scrub up the supervisor's clip-board. While this might provide a funny visual, if it represents a cross contamination concern (which all of these could) it quickly becomes no laughing matter. Prepare Traceability– The more information you have about where your product went, the more efficiently it can be recalled. Reducing risks to consumers and lessening the impact a recall will have on your business. Distributors who track inventory movement manually will be presented with two choices at time of a recall. Call every customer and tell them all to hold product while you sort it out, or try to sort through the drawer full of invoices and POs quickly, hopefully before someone else gets sick. We reviewed some ways to track based on UCC128 codes in Article 95. Be Ready for the Worst – No matter how well prepared there will always be a chance that something will go wrong. When it does, your company needs to be prepared. Before a recall occurs you should: - Train personnel to look up clients that may be affected.
- Prepare a recall or hold script for your employees to use while calling clients
- Prepare a recall or hold form to fax or email to your clients
- Review the steps you will need to take to work with the USDA's Food Safety and Inspection Service to resolve matters quickly.
You know what kind of things can go wrong in your business: Spoilage, contamination, wrong formula mix, tampering, wrong product label, etc. Take a moment to think through each in a worst case scenario, and make sure you're ready to handle it. Recall Insurance – The last topic of note is product recall insurance. Product Recall insurance provides protection for you in the event you must recall any of your products. We know of one processor who has a $1,000,000 policy with a $250,000 deductible and pays $50,000 a year . This might not have kept Topps in business, but it can take the edge off if you can keep the recall narrowed down with good recall practices. Coverage can include product recall expenses and liability to third parties seeking damages because your product recall could cause a loss of income or damage their reputation. If your product poses an imminent threat of property damage or bodily injury, Products Recall Coverage should respond. It will respond to voluntary or involuntary (government or 3rd party-imposed) recalls that satisfy the policy trigger. Product-recall insurance policies take the form of extra-expense coverage rather than legal-liability coverage. I've included a partial list of the expenses you might incur during a product recall in our Thinking Inside the Box section. | Thinking inside the box:
 - Cost associated with notifying customers
- Labor Hours Researching Customers Phone, Fax, Email
- Postage and Printing Expenses
- Radio, Television, Newspaper Announcements
- Shipping Cost
- Labor to Re-Pack
- Labor to Receive and Track
- Extra warehouse and storage expense Separate from "un-contaminated" product
- May require refrigeration
- Actual cost to dispose of the products
- The cost of extra personnel required to conduct the recall
- The recall expenses of any third party for the recall of any product that incorporates your product including the cost to repair or replace such product
- Pre-made Meals - Canned or Bottled Foods - Business Interruption losses of others resulting from the covered incident
- Restaurants and Hotels - Processors and Assembly Shortages - The cost to repair and rehabilitate brand reputation
- The additional cost to purchase substitute goods to replace your products
This is of course on top of the expenses that may occur due to lawsuits and liability from the recalled product itself. |