Since the romaine lettuce contamination just before Thanksgiving, the produce industry has been abuzz with discussions of the increasing incidence of supply chain contamination in recent years.
In a study released by the United Public Interest Research Group, it was reported that food related recalls are up nearly 10% between 2013 and 2018. While the article does allow that improvements in the science and increases in testing since implementation of the FSMA as a factor, it also noted that there were significant gaps in the food safety system. They list four areas where improvements could be made to increase the effectiveness of the food safety system.
- Food Production and Testing
- Inspection and Monitoring
- Recall Effectiveness
Clearly, as an industry, we should all be spending time reviewing the effectiveness of our recall plans and performing mock recalls as the likelihood of experiencing a recall is increasing exponentially for everyone. To assist in making these mock recalls more effective, the industry group PMA provided an article this month on how to respond to a recall and FDA investigation, read the article.
While reviewing your recall plan to ascertain its effectiveness, another major consideration should be minimizing the impact to your company. It was recently reported that the average cost for recall to a food manufacturer can easily reach $10M in direct costs, with additional damages in customer relations, brand disparagement and other intangibles. So, while it behooves companies within the supply chain to evaluate their food safety policies, procedures and ensure compliance with the FSMA and current regulatory standards, the fire hose approach when disaster strikes can cause significant collateral damage if a “recall it all” approach is needed due to lack of prior planning and proper data collection and recording. An important point to remember is that as far as the FDA is concerned, if it wasn’t recorded it didn’t happen. All too often, businesses are still relying on spreadsheets, paper forms and manual data collection to provide the framework for their food safety plans and data retrieval in these systems can be time consuming and error prone.
Leveraging full-featured ERP systems like the ColumbusFood solution for Microsoft Dynamics NAV to perform these functions can offer the ability to record more specific movements within your facilities and allow the organization to target exact points of cross contamination. Features such as:
- Quality Control & Compliance: allows for multiple product tests, their results and the ability to hold and quarantine product which fails these tests
- Process Data Collection: allows for scheduling and recording of bio tests, cleaning or other sanitation related functions for non-product items like machines, utensils, etc.
- Incident Tracking: allows for noncompliance event tracking
- Automated Data Capture system which can allows for efficient result collection and far great confidence in traceability of product moving through the facility.
Consider this sample process:
- Capture field test result at receipt of raw product with Item Quality Tests
- Track product, by lot, from receiving facility to production facility through movements with time and date stamps recorded in the software via standard ledgers
- Record product allocation to a specific machine at a specific time via standard ledgers
- Capture bio test of machine every ½ hour through out the day with Process Data Collection
- Sample product post processing, prior to packaging, capture results with Item Quality Tests
- Capture sanitation of tools and belts every half hour with Process Data Collection
Had each of these events been recorded in a spreadsheet or on paper, traceability becomes a rather time consuming and error ridden process. This leads to the “recall” it all approach because its faster and safer. However, with thoughtful analysis and planning and careful implementation of these software features, the recall scope can be as narrow as possible while remaining safe for the public and transparent to the regulatory organizations. This can result in significant time savings when a recall does happen, along with limiting the very devastating financial impact to your bottom line, and more importantly, your brand.
Contact your Columbus Food consultant today to learn how these important features can benefit your company’s food safety plan. We can help you analyze the feature integration to your best advantage so that you can confidently answer “YES” when the question of targeted and accurate recall scope comes up.
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