During my visits, I am working with farmers to build their food safety manual (Manual template 1, Manual template 2, Manual template 3). Going over the food safety logs (Logs 1, Logs 2, Mock Recall Log) a farmer asked me ‘Why do I need to complete a mock recall I am very small?’ There are not a lot of examples of how small farms recall product because the media usually follows the big companies associated with high numbers of illnesses and affected product.
During June, a small farmer producing sprouts received an email about 12 hours after Germany announced the E. coli outbreak had been linked to sprouts. The email was from a community supported agriculture (CSA) customer claiming to have received foodborne illness from their sprouts and therefore no longer trusted the farm’s produce. The farm immediately stopped production and began implementing their good agricultural practices (GAPs) traceability system. The farm proceeded by contacting their customers and canceling all orders that were due to be delivered the next day. Additionally, they asked wholesale customers to remove their sprouts from sale immediately and record the amount disposed of so that the farm could reimburse them. The farm did not bother with individual customers since they had no way of contacting them personally. The farm took the remaining sprouts that were due to be delivered the next day to the dump.
Aside from one customer complaint which was not confirmed, the farm received no other complaints but this farm no longer intended on selling sprouts. Here are some examples of mock recalls preformed by larger companies (Mock recall 1, Mock recall 2).
To be prepared for a recall situation, farmers can complete a mock recall annually to test the plan they have in place. A mock recall is a simulated recall exercise with a time limit to complete the entire exercise (i.e. 2 hours). Recalls are voluntary procedures conducted to identify and recover potentially adulterated, misbranded, and/or hazardous foods from trade and/or consumer channels effectively. For information on currents recalls go to the FDA recall website.
To perform a recall, you will need to be able to trace each load leaving your farm to the field of origin and date of harvested. You will need to establish a code lot numbering system (i.e., lot or product codes). Every package of outgoing product must have a traceability code, such as a Julian date or a specific sequential code. Regardless of how the code is made, it should provide the farm with information on how to identify the produce. In fact it can separate the amount of product implicated in a recall such as if one day is a lot then the minimum quantity implicated would be the entire day’s production.
Here is a checklist for your recall plan:
1) Be sure names and phone numbers of customers who need to be contacted are available and current.
*For farmers with only one CSA program, you should know their main contact and a back up for them.
2) Be sure of names and phone numbers of media representatives, proper authorities (FDA, NCDA, etc.), and legal council.
3) Identify the problem and assess the health risks.
4) Determine the products and lot numbers involved.
5) Determine quantities involved.
6) Determine current inventory on the premises.
7) Determine the amount of product in the marketplace.
8) Identify the customers who have received the product.
9) Collect pertinent documentation regarding the affected product.*Inputs and outputs of affected field, notes on unusual events (flooding, wildlife activity, etc).
10) Determine the percent effectiveness of the mock recall
The total amount of suspect product must equal the sum of the product shipped and the amount still in inventory.
A – total amount of product produced
B – Amount still on inventory
C – Amount delivered to customers
D – Incidental usage (product dropped on ground, etc.)
11) Outline the shortcomings in our recall plan and what corrective actions will be taken. *For example, taking longer than 2 hours and not being able to account for 100% of the product.
*Testing these programs is the best way to ensure their effectiveness and to best ensure preparedness for an actual recall.
A majority of our farms sell directly to the consumer through roadside stands and farmers’ markets. In the event of a recall contacting these types of customers can be difficult to unrealistic. During my visits I brainstorm with farmers ways of contacting these types of patrons, such as through email sign up sheets, website notifications, and signs at the stand/farmers’ markets.