Trouble at t'millTrouble at t'mill

If a recall occurs at a feed mill, there are a number of things that need to happen. All of them require communication and planning.

The following slides outline the series of steps taken in a recent feed product recall for poultry products from the point when an issue was identified. Issues can be identified by your customer, retailer or internally by your own team.

• Additional information can be found at the MPI website • http://www.mpi.govt.nz

• This presentation also includes some talking points for you to consider when dealing with or planning your recall training and preparedness.

• This presentation is not considered to be a complete guide and you should always seek further information.

If a recall occurs at a feed mill, there are a number of things that need to happen. All of them require communication and planning.

The following slides outline the series of steps taken in a recent feed product recall for poultry products from the point when an issue was identified. Issues can be identified by your customer, retailer or internally by your own team.

• Additional information can be found at the MPI website • http://www.mpi.govt.nz

• This presentation also includes some talking points for you to consider when dealing with or planning your recall training and preparedness.

• This presentation is not considered to be a complete guide and you should always seek further information.

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Product Recall or Product Withdrawal?Product Recall or Product Withdrawal?

•Product Recall• A recall involves removing unsafe product from the distribution chain

extending through to product already sold to consumers, and hence the public needs to be informed. Notification to statutory authorities and media is required.

•Product Withdrawal• A withdrawal stops at the point at which food is sold to consumers –

only suppliers and retailers will be involved.• Withdrawals do not require notification to statutory authorities or

media.

•Product Recall• A recall involves removing unsafe product from the distribution chain

extending through to product already sold to consumers, and hence the public needs to be informed. Notification to statutory authorities and media is required.

•Product Withdrawal• A withdrawal stops at the point at which food is sold to consumers –

only suppliers and retailers will be involved.• Withdrawals do not require notification to statutory authorities or

media.

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Step 1: Assessment of the Issue and Potential Risk

Step 1: Assessment of the Issue and Potential Risk

• A Recall Management Team was assembled, made up of the management team and key functional members (3 meetings over 3 consecutive days)

• Reviewed all data that was identified in the issue

• Consulted with suppliers and experts on questions raised at meeting• To gain a better understanding of risk and issue

• Identified all products affected including batch codes, sales volumes and distribution

• Based on all facts known, a decision was made to notify MPI about the issue and to put all poultry bagged products on hold

• A Recall Management Team was assembled, made up of the management team and key functional members (3 meetings over 3 consecutive days)

• Reviewed all data that was identified in the issue

• Consulted with suppliers and experts on questions raised at meeting• To gain a better understanding of risk and issue

• Identified all products affected including batch codes, sales volumes and distribution

• Based on all facts known, a decision was made to notify MPI about the issue and to put all poultry bagged products on hold

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Step 2: Notified MPIStep 2: Notified MPI

• Contacted MPI verbally to identify the issue at hand• This was followed up with formal notification• Received a formal reply next day• Held 4 meetings over 4 consecutive days via phone conference with MPI

• MPI Key Outcomes • MPI completed its preliminary risk assessment and instructed the company to

proceed with the public recall of the poultry bagged lines• MPI did not require a health advisory within the public recall notice• MPI advised the following government offices:

• Prime Minister’s Department• Ministry of Food Safety• Ministry of Health

• Contacted MPI verbally to identify the issue at hand• This was followed up with formal notification• Received a formal reply next day• Held 4 meetings over 4 consecutive days via phone conference with MPI

• MPI Key Outcomes • MPI completed its preliminary risk assessment and instructed the company to

proceed with the public recall of the poultry bagged lines• MPI did not require a health advisory within the public recall notice• MPI advised the following government offices:

• Prime Minister’s Department• Ministry of Food Safety• Ministry of Health

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Step 3: Preparing to RecallStep 3: Preparing to Recall

• Product specifics• Identified and confirmed what products fell within the recall period and what

the batch codes were• Identified what product we still had in our possession• Identified what products we had to recall – didn’t want to recall products that

we had and weren't out at store or customer level.

• Communications• Enlisted a PR’s expertise to “wordsmith”• Created communications

• Letter to retailer• Letter to customer• Customer enquiry form• Recall media statement• Recall flyer for on shelf• Customer Q&A and second-tier question process• Recall notice as per MPI requirements

• Product specifics• Identified and confirmed what products fell within the recall period and what

the batch codes were• Identified what product we still had in our possession• Identified what products we had to recall – didn’t want to recall products that

we had and weren't out at store or customer level.

• Communications• Enlisted a PR’s expertise to “wordsmith”• Created communications

• Letter to retailer• Letter to customer• Customer enquiry form• Recall media statement• Recall flyer for on shelf• Customer Q&A and second-tier question process• Recall notice as per MPI requirements

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Recall NoticeRecall Notice

• Recall notice requirements:• List company name and address• Identify the products in the most

consumer-friendly way• Be a set size• Detail the exact problem with the

product• Not have any promotional info.

included• To be published in all regional

newspapers• Posted on website • Posted on MPI recall website• Approved by MPI

• Recall notice requirements:• List company name and address• Identify the products in the most

consumer-friendly way• Be a set size• Detail the exact problem with the

product• Not have any promotional info.

included• To be published in all regional

newspapers• Posted on website • Posted on MPI recall website• Approved by MPI

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Step 4: Communication PlanStep 4: Communication Plan

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Step 5: Commence RecallStep 5: Commence Recall

• Recall communications• Notifications went to all retailers• Recall notice was published in required newspapers• Communication on how to get product back sent to retailers and head offices• Key stakeholders were also communicated to, including suppliers• Communications went to all internal staff so they were aware of what was

occurring.

• Product Return Process• A process was created to get all product recalled back to our distribution

centre.

• Recall communications• Notifications went to all retailers• Recall notice was published in required newspapers• Communication on how to get product back sent to retailers and head offices• Key stakeholders were also communicated to, including suppliers• Communications went to all internal staff so they were aware of what was

occurring.

• Product Return Process• A process was created to get all product recalled back to our distribution

centre.

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Step 5: Retailer Product Recall ProcessStep 5: Retailer Product Recall Process

• Pick-up of “Store Inventory Stocks” • From the Fax Recall Sheets we have compiled a full list of all stocks in stores • Pick up of the store product will occur over Friday 24th June and Monday 27th

June • All stocks received back into our distribution centres will be reconciled against

the Fax Recall Sheets received from each store • Arrange for credits to be processed on all store stocks that are received in line

with the Fax Recall Sheets – credits will be processed at current wholesale pricing

• Customers Returning Product • Provide affected customers with feed vouchers that can be used for any of our

bagged feed product brands • Only provide replacement feed vouchers to customers that bring in full or part

full bags of affected feed. We are unable to provide any vouchers for replacement product on the return of empty bags as this is a product recall process

• When we receive the fax copy of the Customer Return Form, contact each store to arrange for pick up of returned product

• Pick-up of “Store Inventory Stocks” • From the Fax Recall Sheets we have compiled a full list of all stocks in stores • Pick up of the store product will occur over Friday 24th June and Monday 27th

June • All stocks received back into our distribution centres will be reconciled against

the Fax Recall Sheets received from each store • Arrange for credits to be processed on all store stocks that are received in line

with the Fax Recall Sheets – credits will be processed at current wholesale pricing

• Customers Returning Product • Provide affected customers with feed vouchers that can be used for any of our

bagged feed product brands • Only provide replacement feed vouchers to customers that bring in full or part

full bags of affected feed. We are unable to provide any vouchers for replacement product on the return of empty bags as this is a product recall process

• When we receive the fax copy of the Customer Return Form, contact each store to arrange for pick up of returned product

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Step 5: Retailer Product Recall ProcessStep 5: Retailer Product Recall Process

• Ordering New Replacement Stocks • June product fully tested and available for distribution by late next week • We will begin accepting orders for replacement product from Monday 27th

June

• Separation of new stock going out and recalled stock coming in was critical

• Product needed to be identified clearly• Product not even in the recall came back

• Ordering New Replacement Stocks • June product fully tested and available for distribution by late next week • We will begin accepting orders for replacement product from Monday 27th

June

• Separation of new stock going out and recalled stock coming in was critical

• Product needed to be identified clearly• Product not even in the recall came back

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Step 6: Handling Recalled ProductStep 6: Handling Recalled Product

• Full Pallet-Bagged Product• Full pallet-bagged products tested and reworked into production subject to

testing• Subject to MPI approval of process

• Opened/Partial-Bagged Product• Opened (partial) bags – safely disposed of • Unopened (full) bags – dairy rework

• Storage and handling of the product returned• Isolation from other fresh stock• Management of mite and other infestation risks• Product outside the recall – old stock

• Full Pallet-Bagged Product• Full pallet-bagged products tested and reworked into production subject to

testing• Subject to MPI approval of process

• Opened/Partial-Bagged Product• Opened (partial) bags – safely disposed of • Unopened (full) bags – dairy rework

• Storage and handling of the product returned• Isolation from other fresh stock• Management of mite and other infestation risks• Product outside the recall – old stock

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Step 7: Effectiveness of RecallStep 7: Effectiveness of Recall

• Percentage of recall received back:• Percentage of recall received back:

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Unsold Retailer Product

Region Retailer Claims (Bags)

Retailer Claims (MT) Collected (MT) Collected (%)

South Island 2,450 61 63 >100% North Island 6,890 173 166 96%

Total 9,340 234 229 98% Customer Claims

Region Customer Claims (Bags) Claimed (MT) Collected (MT) Collected (%)

South Island 125 3 2 66% North Island 428 11 7 63%

Total 553 14 9 64%

Step 7: Effectiveness of RecallStep 7: Effectiveness of Recall

• Monitored calls to customer services and nature of call:• Monitored calls to customer services and nature of call:

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Date(s) Total Calls

Store Enquiry

End User Enquiry

*Elevated %

Comfortable %

Concerned June 24 64 15 49 8 80% 20%

June 25/26 18 0 18 2 80% 20%

June 27 52 10 42 4 80% 20%

June 28 46 19 27 1 78% 22%

June 29 32 11 21 1 90% 10%

June 30 37 12 25 2 70% 30%

July 1 44 10 34 6 80% 20%

July 4 21 6 15 1 90% 10%

July 5 12 3 9 0 100% 0%

July 6 8 3 5 3 63% 37%

Step 8: Root Cause AnalysisStep 8: Root Cause Analysis

• Complete root cause investigation• Meeting with MPI – Audit

• Review of recall documentation and processes to date• Outcome: MPI comfortable with actions and recall processes• Ongoing correspondence will occur between both parties as further

investigation is conducted• Currently using a hold and release programme for poultry products

• This monitoring and communication is still ongoing

• Complete root cause investigation• Meeting with MPI – Audit

• Review of recall documentation and processes to date• Outcome: MPI comfortable with actions and recall processes• Ongoing correspondence will occur between both parties as further

investigation is conducted• Currently using a hold and release programme for poultry products

• This monitoring and communication is still ongoing

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What we learned / What we recommendWhat we learned / What we recommend

• Recall Management Team• Dealing with MPI• Dealing with Retailers• Quality Control

• Recall Management Team• Dealing with MPI• Dealing with Retailers• Quality Control

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Recall Management TeamRecall Management Team

• Recommend establishing formal Recall Response Team • Leader with clear accountability• Clear roles and responsibilities • Have the ability to take actions away and execute with greater team• Have one key contact to liaise with MPI• Small and manageable expands to large and executable

• Must convene early • As soon as there is any indication of an incident that may escalate • Before Police, Health or any other external party become involved

• Must think through the consequences of any actions and ensure process is objective and not emotive

Practice / Mock Recalls on regular basis to ensure participants are aware of process and barriers to executing correctly

• Recommend establishing formal Recall Response Team • Leader with clear accountability• Clear roles and responsibilities • Have the ability to take actions away and execute with greater team• Have one key contact to liaise with MPI• Small and manageable expands to large and executable

• Must convene early • As soon as there is any indication of an incident that may escalate • Before Police, Health or any other external party become involved

• Must think through the consequences of any actions and ensure process is objective and not emotive

Practice / Mock Recalls on regular basis to ensure participants are aware of process and barriers to executing correctly

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Dealing with MPIDealing with MPI

• Give MPI the information it asks for and no more• MPI wants specifics and not all the data

• Give MPI solutions based on industry knowledge and experience or MPI will have to go away and find solutions

• If the issue spans two different areas, MPI will need to consult other MPI departments

• The responsibility for managing any risks associated within the recall is ours, not MPI’s. MPI will guide but not take ownership

• MPI works office hours

• MPI will act if you don't

• A relationship with MPI helps in times such as recalls

• Give MPI the information it asks for and no more• MPI wants specifics and not all the data

• Give MPI solutions based on industry knowledge and experience or MPI will have to go away and find solutions

• If the issue spans two different areas, MPI will need to consult other MPI departments

• The responsibility for managing any risks associated within the recall is ours, not MPI’s. MPI will guide but not take ownership

• MPI works office hours

• MPI will act if you don't

• A relationship with MPI helps in times such as recalls

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Dealing with RetailersDealing with Retailers

• Confusion at store level will occur if communication isn't clear and the recall process isn't simple and workable:

• Product continued to be sold in some cases• Some retailers were not giving product back to transport companies• We received product back that was not in the recall

• Don’t overpromise to the stores• Product removal from stores’ timelines – if timelines are committed to, make

sure you stick to them

• Approx. 40% of product was returned without the required identification information

• Follow-up communication with retail stores (clarify process)• Don’t assume retailers’ head offices have sent the stores all the info. and

correct instructions

• Confusion at store level will occur if communication isn't clear and the recall process isn't simple and workable:

• Product continued to be sold in some cases• Some retailers were not giving product back to transport companies• We received product back that was not in the recall

• Don’t overpromise to the stores• Product removal from stores’ timelines – if timelines are committed to, make

sure you stick to them

• Approx. 40% of product was returned without the required identification information

• Follow-up communication with retail stores (clarify process)• Don’t assume retailers’ head offices have sent the stores all the info. and

correct instructions

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CommunicationCommunication

• Create a Communication Plan• Who, when, how, and what

• Internal people need to be told the same as external

• Make it as simple as possible to follow

• Ensure that communication has been passed on every level required to execute the recall – both external and internal

• Subject to legal privilege• Emails that are distributed internally may be discoverable in an external

investigation• Documents recording investigation findings should be kept confidential, where

possible marked: ‘Subject to legal professional privilege’ and communicated directly to the lawyer for the purpose of obtaining advice.

• Create a Communication Plan• Who, when, how, and what

• Internal people need to be told the same as external

• Make it as simple as possible to follow

• Ensure that communication has been passed on every level required to execute the recall – both external and internal

• Subject to legal privilege• Emails that are distributed internally may be discoverable in an external

investigation• Documents recording investigation findings should be kept confidential, where

possible marked: ‘Subject to legal professional privilege’ and communicated directly to the lawyer for the purpose of obtaining advice.

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Quality ControlQuality Control

• Traceability is critical – on raws and finished product• The more traceable your product is, the less you will have to recall• Batch coding needs to be clear and easily readable

• Make haste slowly!• You need to act fast but make sure you have all the facts first

• Mock Recalls – Practice makes perfect• Knowing what to do is 75% of a recall• Identify where your process breaks down and could cost you more• MPI has recall plan templates

• Validation of processes. • Critical control points – confirm they do what they are meant to• Flushes and safe feed matrix – confirm they result in safe process• Testing programmes – confirm they capture what is needed

• Traceability is critical – on raws and finished product• The more traceable your product is, the less you will have to recall• Batch coding needs to be clear and easily readable

• Make haste slowly!• You need to act fast but make sure you have all the facts first

• Mock Recalls – Practice makes perfect• Knowing what to do is 75% of a recall• Identify where your process breaks down and could cost you more• MPI has recall plan templates

• Validation of processes. • Critical control points – confirm they do what they are meant to• Flushes and safe feed matrix – confirm they result in safe process• Testing programmes – confirm they capture what is needed

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