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New food-safety law isn’t the only reason to have a recall plan

by Amy Philpott | April 25, 2011

The first few hours of a recall are the most crucial. There is little time to develop strategies to protect public health and repair a company’s reputation. Yet it is critical that a company demonstrate it can quickly and accurately execute all aspects of a recall. The best way to ensure this is to have a plan.

Under Section 103 of the 2010 Food Safety Modernization Act, mandatory “preventative controls” include a recall plan. But this new food-safety law isn’t the only good reason for having a recall plan.

Produce companies plan virtually every aspect of their existence. They invest in a financial plan, a marketing plan, a business plan, a food-safety plan and even a succession plan. So why do so few have a written recall plan? Here are three of the most common excuses:

• It’s too expensive or time consuming.

• A recall won’t ever happen to us, and if it does, we’ll just hire a consultant.

• We are already prepared because we have a great traceability system.

Planning does take time, and it almost always takes money, but I have yet to work with a company that didn’t save both by having a plan in place before a recall hit. Leading up to, during and after a recall, an overwhelming number of decisions must be made quickly and accurately. Having a plan in place ensures that resources are not wasted and that the most critical decisions receive attention when they should.

Also, hoping that a recall won’t happen or that, if it does, a consultant will fix it, leaves the future to chance — which is never an advisable business strategy. Furthermore, educating someone during a recall about the company, its products and its culture takes time and patience at a time when both are in short supply. It is more efficient to involve third-party experts during the planning stage.

Finally, many companies do have great traceability systems, but a recall is more than tracing product forward and back. A recall involves verifying, tracing, removing and disposing of product; it includes reaching out to customers, informing consumers and talking to media. There are more than a dozen communication documents targeting at least six different audiences that a company must distribute within hours after deciding to recall. A recall plan provides templates for these documents, lists, reports and more; it is a company’s roadmap for who will do what, when and how. Notably, a recall plan focuses equally on logistics and communications.

One of the more common mistakes that companies make is underestimating the communication component of a recall. Recall communications are distinct from other types of communications produce companies engage in. They differ greatly from regular public health communications, which strive to generate a permanent change in consumer behavior — for example, eating more fruits and vegetables.

Recall communications aim to elicit a temporary consumer behavior. They must persuade people to take one very specific action temporarily, and then be equally persuasive in convincing them to reverse that behavior. Recall communications also differ from marketing communications, which are primarily designed to sell a good or service. While marketing focuses on promoting product benefits, recall communications focus on communicating risk, and must therefore be sensitive to how consumers perceive risk.

Risk communication principles show that the less control consumers think they have, the greater their perceived risk and the more likely it is that unrelated factors will take on substantial meaning and importance. This is why consumers are often less accepting of the risk associated with a fresh produce recall than they are of, say, the risk of crossing the street or driving a car. They perceive the risk from a fresh produce recall to be:

• Imposed on them (vs. voluntary).

• Controlled by others (vs. an individual’s control).

• Resulting from industry (vs. natural).

• Affecting children or vulnerable populations more than others.

In addition, the level of anxiety and perceived risk increases when the cause of the recall is uncertain or the consequences are severe — for example, if illnesses or deaths are involved. Recall communications must consider these factors and should convey a company’s compassion, commitment and cooperation as well as provide facts and information that protect public health.

A recall plan will not anticipate every possible situation, nor will it compensate for poor execution. And it definitely will not prevent a recall. But a recall plan will save you time and your company money. It will instill confidence in your company’s ability to respond, and it will ensure a more efficient and complete response aimed at protecting public health and rebuilding your company’s reputation.

Even if the new law didn’t require it, a written plan that includes both recall logistics and communications is good business.

(Amy Philpott is senior director at Watson/Mulhern LLC, a public communications firm in Washington, DC, specializing in issue management and risk communications in the life sciences realm. Formerly vice president of communications at United Fresh Produce Association, she currently assists companies and organizations in the fresh produce, nut and candy industries develop recall communication plans and media relations strategies. She will be speaking May 4 at the food-safety demo center during the United Fresh convention in New Orleans.)