Take Note: Record-Keeping Is the Key Element in a Recall

If it seems like food and consumer product recalls are everywhere, you’re not imagining things. They are. Every day brings more news about another danger consumers face from a food contaminant like Listeria or a faulty appliance that’s in nearly every home.

Since 2007, the increase in food and consumer product recalls has created headlines, attracted enormous attention on social media and prompted new federal legislation. Add to the mix lawsuits from plaintiffs’ attorneys and criminal scrutiny from the U.S. Justice Department and it’s a wonder that any company can conduct a proper recall while continuing to operate its business and protect its brand.

Recalls are complicated, time-consuming, destructive and expensive. That’s why building and testing a recall crisis plan is essential for any food, drug or consumer product company today.

But even companies with recall plans are being undone because they’re too often overlooking what experts now say has evolved to be the most important element in a recall – accurate record-keeping.

“Proper documentation across all aspects of the business, from manufacturing and shipping data to consumer complaints and paperwork required by regulatory bodies, is a crucial part of executing a successful recall,” says Steve Edwards, Director of Client Solutions at Stericycle, a company that manages as many as 1,000 recalls each year. “A company can quickly fall out of compliance and accrue regulatory penalties and fines if even the smallest piece of data is overlooked during the documentation process.”

According to Joe Levitt, the FDA’s former top food regulator who now serves clients as a Partner at law firm Hogan Lovells, there are five essentials necessary for a company to successfully navigate a food recall:

  1. A written and practiced protocol for keeping food safe during production
  2. Ability to quickly trace ingredients through suppliers
  3. A written recall plan that has been tested
  4. A food-safety expert who can work with the FDA
  5. Accurate records for all of the above

Of all these, Levitt warns, the most important is to have complete and careful records for everything your company does regarding food safety.

“If it isn’t written down, it doesn’t exist,” says Levitt. “And if it doesn’t exist, the FDA is likely to assume that you don’t know what you’re doing. If that happens, your whole business can be lost.”

By that analysis, even a perfectly executed recall can result in a company’s failure when the paperwork is neglected. So take the extra time to document and store every step before, during and after a recall.

Hope you’ve been taking notes.

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