Identify all key personnel
Practice, practice and practice
- Adulterant/Positive Product Sample – If FSIS (or a state/customer) samples your product and it tests positive for an adulterant, can you “correctly” identify the product implicated by the sample.
- With FSIS testing, many recalls have occurred following an agency positive, not because the establishment did not hold product, but because it did not hold all product represented by a sample. On your next agency sample, pretend it is positive and that the agency alleges that you did not hold all implicated product. Could you and your team support your lotting practices to demonstrate that all implicated product was indeed held?
- With a state or customer test, the product is often already in distribution. Determining what product is implicated entails tracing product back up from the positive to the “lot” of production implicated, supporting the decision as to which product is implicated, and then tracking downstream to identify all customers who received product from the implicated lot.
- Undeclared Allergen — There have been simply too many recalls based on undeclared allergens. In part, this is caused by use of the wrong label during production. Other times, a supplier might have changed its formulation to add/change an allergen. A mock recall based on a change in ingredient (the addition of a previously undeclared allergen) helps an establishment determine if it can trace an ingredient through its process, identifying all products which could be implicated.
- Foreign Material — Conducting a mock recall on potential foreign material provides the best experience in determining whether a recall is necessary. In these cases, it is balancing the likelihood other contaminated product is in the market with the potential risk posed by the foreign materials. This exercise could have the establishment reaching out to its experts.