The fourth quarter surge was not out of line with historical averages, an official with the company said. But implementation of the Food Safety Modernization Act could push that number high in the near future.
The report, called the ExpertRECALL Index, was compiled by Stericycle ExpertRECALL, a company that helps clients manage recalls in the consumer product, pharmaceutical, medical device, juvenile product, and food and beverage industries. “Right before FDA’s announcement of two major requirements proposed under FSMA, the agency documented 552 food recalls, representing a 33 percent increase over the previous quarter and reaching the highest level of recall activity in more than two years,” Mike Rozembajgier, vice president of recalls at Stericycle ExpertRECALL told FoodNavigator-USA.
“Whenever new regulations are passed and enacted, we usually see more violations of the new rules, especially immediately after implementation.
That obviously could lead to an increase for recalls. The goal is for that to eventually to come down,” he said.
Peanut recalls played a role
According to the report, of the recalled food products announced during the fourth quarter, 94 percent fell within the Class I designation as the units could cause serious health consequences or death. Salmonella concerns were the number one cause of food recalls followed by undeclared allergens or other allergen concerns.
A big part of the fourth quarter uptick in recalls—164 out of the 522 total—was associated with peanut products tainted with salmonella coming out of the Sunland plant in Portales, New Mexico, the nation’s largest organic peanut processing plant. That recall event started in late September 2012, and generated multiple recall data points as more and more product lot numbers were identified. FDA eventually used its authority under FSMA to suspend the company’s food facility registration, and the company was out of production entirely until it could satisfy regulators that the contamination problem was solved.
The struggles Sunland had with bringing the episode to a satisfactory conclusion highlights what Rozembajgier said are the four goals in a successful recall:
“Protect the public, first and foremost, protect the brand, look to close out the recall as soon as possible, and protect the environment with proper disposal of recalled material, though that doesn’t come into play as much in food recalls,” he said.
Practice makes perfect
Though recalls by their nature are negative events, planning and practice can make them less painful, Rozembagjier said.
“In theory if you are a food company you should have a recall plan in place. They have to have a plan in place but the plan itself has to be tested. More often than not companies put the plan in place and then think that they are done.
“You have to make sure that the people that are involved in it have been through the cycle, been through the repetition and you can identify and gaps or holes.”
The plan needs to address actions the company itself will take, but also needs to involve partners up and down the supply chain. And while Rozembagjier said practice can help make perfect, companies still need to bear in mind that recalls don’t always (in fact, rarely) go according to plan.
“Elements of things that happen when the actual recall occurs: How long did it take to determine how much product was affected? Did you do a good enough job communicating to the market what products were affected? Are you responsive enough to the market to make sure you get your product back? And finally, how flexible are you? We like to say that no two recalls are the same,” he said.
The draft HARPC rule under FSMA addresses the recall issue from a preventive aspect, Rozembagjier said.
“As the agency continues to shift its focus towards prevention rather than simply reacting to foodborne illness outbreaks, we can expect the FDA to pay more attention to what companies are doing to ensure our food is safe and prevent recalls from occurring. Companies with a recall plan that is ready are likely to best weather the impending storm of increased regulatory scrutiny,” he said.