Tony Hines, head of food security and crisis management manager, Leatherhead Food Research, told FoodManufacture.co.uk that, under EU Food Safety Requirement, Article 14, consumers can expect to purchase food fit for consumption, not injurious to health and consistent with label descriptions.
Under EU General Food Law, Article 19.1, Hines said that suppliers, manufacturers, retailers who import, produce, process or distribute foodstuffs that fail to comply with this article should immediately start proceedings to withdraw the product from the market and inform the competent authorities.
Consumer, brand or law?
But what comes first, the consumer, brand reputation or legal compliance? “Is it tempting to receive one or two complaints relating to a foreign body and hope you do not get any more, or to immediately withdraw or recall the product?" said Hines.
"As a good crisis manager will say, get it right and no-one remembers, get it wrong and no-one forgets."
Julia Johnson, senior consultant on the Razor risk and crisis management service for College Hill, said: “Recalls happen every week and largely go unheralded in terms of reputational impact … when handled efficiently and competently; the extent of the problem is quickly identified, a swift decision made to recall, the regulatory authorities, retailers and consumers notified effectively and products retrieved
“Bungled recalls are those where there is no clear process or decision-making, or where there are delays in admitting the problem, or worse, where the problem, or risk of a problem, is ignored or even covered up, only to come to light later. These are more likely to inflict lasting damage to reputation.”
Successful product recalls should be prepared in advance, Johnson said, with an incident team identified, a recall plan written and people and processes tested via simulation exercises.
Once a firm finds itself in a recall/withdrawal situation, Hines said, details can appear on websites, in retail stores and even (in rare cases) the national press; the UK Food Standards Agency (FSA) has an alert system, while charities like the Anaphylaxis Campaign can send an SMS message to lists of allergenic consumers when risky products are identified.
Johnson said that social media was an increasingly useful tool during product recall cases, and that use of P2P platforms such as Twitter, Facebook was the biggest factor upon which Razor is currently advising clients on regarding planning about potential recalls.
“What better way to reach consumers – often already engaged in your brand – at risk from a hazardous product, than via social media?” She also said it was one way of showing diligence, although it should not obviate good planning and preparation.
“However, use of social media channels is causing traditional customer care-lines to be bypassed, with product problems increasingly first reported in cyberspace. Food manufacturers must monitor social media to pick up and respond to emerging issues.”
Consumers trust brands, and Hines said a failure to risk assess correctly and quickly may lead to a backlash, normally as a result of unflattering media coverage.
“The old saying, the bigger the brand the bigger the coverage is as true today as it was 20 years ago,” Hines said.
“A consumer affairs correspondent does not get many opportunities to knock celebrities, wars, politics, banks and job losses off the front page. A great food scare can do this and … sell newspapers.”
Consumers also dislike confusion, Hines said, and cited the recent dioxin scandal surrounding egg products in Germany as a “classic case” of miscommunication. “The authorities said the products are safe, but some retailers removed them from sale, others did not.”
Johnson said that trade associations such as the UK-based Food & Drink Federation should communicate industry-wide issues, ensuring consistency and diverting attention from individual companies; manufacturers should also follow updates from the likes of the FSA to plan next steps.
“Speed of action and communication are vital, but it is equally important for manufacturers to take a little time to ensure that information is accurate. It is not uncommon … for the recall of an initial batch to be followed shortly after by the recall of further batches, which can confuse consumers,” she said.
Risk assessment processes
Hines said one critical question during food scares is whether Hazard Analysis Critical Control Points (HACCPs) have been compromised. These serve a specific food safety purpose and a well-documented, trained HACCP team and plan form a major part of any potential due diligence defence in case of court action, and are critical to future prevention, he explained.
But Johnson said a surprising number of UK food producers thought a rigorous HACCP system (which she said the majority implement) gave wholesale coverage regarding risk.
“Typically, however, HACCP is used only with reference to the operational part of manufacture and not to address risk factors away from the production line."
She advised food producers to conduct risk analysis of commercial systems, reputational, security, supply chain, people and regulatory risks at least once a year, and to put plans in place to mitigate the most likely and/or serious risks, while running simulation exercises.
Adding value illegally
Despite recent incidents – BSE, foot and mouth, Sudan 1 – Hines said that the UK has a well-tested food safety system (alongside EU port controls) to protect health, in addition to a developed retail sector where food chain management is a pre-requisite of trade.
“However, as we have seen with melamine and Sudan 1 contamination, someone somewhere is always looking for the next opportunity to add value to food illegally. In my opinion, it is this type of incident where we are most at risk,” he said.
“Our food supply chain has become a ‘web’ where products and ingredients move swiftly around the world. Incident planning involving a number of agencies and government departments is now common.”
But Johnson warned that UK food and drink manufacturers do not have sufficiently robust crisis management procedures in place, which she said was surprising given stiff regulatory requirements and legal liabilities.
“It is difficult to put a figure on the number of companies without crisis management systems in place, but we know from our experience that for many of them it is not a priority and often they make do with the bare minimum of a process," she said.