With an estimated 10 million beef burgers taken off of supermarket shelves in the last couple of days, the rather surprising discovery of horse DNA in supermarket beef products demonstrates how no food business, however committed to quality, is immune from a product recall. Whilst a somewhat unusual scenario, Deborah Polden of Eversheds’ Food and Drink Sector group has issued this timely reminder to food businesses of the steps they should take to ensure they are in a position to act quickly should an issue arise.
While food businesses must do all they can to ensure the safety and quality of their products, as this latest news demonstrates it is simply not possible to eliminate the risk of a recall. Businesses that are alive to this risk and have an established recall plan in place, which is updated and tested regularly, tend to fare far more effectively in a crisis. With effective PR and decisive action, a product recall can provide an opportunity to emphasise the brand’s reputation for safety, quality and customer service. On the other hand, delaying taking action, or even worse, turning a blind eye to product issues, can lead to bad publicity and be hugely damaging to the brand.
What should a product incident plan involve?
Keep an up-to-date list of relevant contacts and their details: customers; suppliers; the Food Standards Agency; local Environmental Health officers; insurance brokers; laboratories; PR advisers; legal advisers. Mobile numbers will enable you to contact them without delay in an emergency.
>Establish a major incident team within the business who will be convened in a crisis, including a senior decision-maker plus representatives from the quality, sales and finance functions. A written record of the crisis team’s discussions and decisions should be kept – this may reduce the scope for arguments as to whether the business acted reasonably in the event of a subsequent investigation. Take care however not to create damaging documents which may be used against you in any subsequent supply chain dispute.
Seek to identify the extent of the problem so you can react proportionately. The extent of any action needs to be carefully considered – a business will not want to withdraw or recall more product than necessary, but if a further recall is necessary, this is likely to damage trust in even the most established brand.
It is vital to have a PR strategy to protect your reputation and your brand. The public perception of a problem can be far worse than any health risk, as this latest issue demonstrates only too well – the products pose no risk to health, but there is a particular cultural aversion to eating horsemeat in the UK.
Identify a spokesperson, and ideally provide them with media training in advance of any issues arising. If an incident arises, ensure they are fully briefed. Anticipate difficult questions in advance and prepare a response. Be open with the media, but stick to the agreed company response.
Customer service staff should also be trained on how to respond to a product incident. Depending on the scale of the problem, it may be necessary to set up a dedicated team and separate hotline number. If an issue arises, anticipate potential questions and prepare a script for customer service staff to follow to ensure a consistent response.
Ensure a system is in place to monitor any action taken. The Food Standards Agency and local Environmental Health officers will expect to be kept informed of the situation as it develops and the volumes of stock returned/removed from shelves. If disposal takes place through a third party, ensure that you receive certificates confirming that product was disposed of in accordance with appropriate procedures, so that there is no possibility of illicit on-sale down other channels.
If you have a social media presence, use it to your advantage! It can be an effective way of engaging with and reassuring customers, and quickly correcting inaccurate rumors that can rapidly spread across the internet. Recent case studies suggest that where a business has a social media presence but suddenly goes quiet in the face of a product incident, this leads to frustration and huge consumer dissatisfaction.