Food Protection Trends - May/June 2017 - 164

table 1. detailed profiles of in-depth interviewees

Industry

Government

Interviewee Code

Industry/Government Agency

Organization
Size*

IND-1

Director of Quality and Food Safety

Large

IND-2

Vice President of Quality Assurance, Product Compliance and Nutrition

Large

IND-3

Consultant

-

IND-4

Senior Vice President of Operations and Human Resources

Medium

IND-5

Food Safety Quality Assurance Team Lead

Large

IND-6

Director of Regulatory and Technical Services

Large

GOV-1

Industry (Former Senior Federal Official)

-

GOV-2

Federal

-

GOV-3

Provincial

-

*Organization size based on Canadian Industry Statistics (CIS) criteria
Using mock recalls as a training tool provides newcomers
with a hands-on learning opportunity and is perceived to
be the most effective manner to teach accountability and
authority in recall situations.
"If we have new people coming in, depending
on where they're working, generally if the core team
gets affected, then quite honestly, the mock recalls
are the best training ground ever... And what we'll
do is hold mock recalls, or info sessions, to walk them
through what their responsibilities are, what our needs
are from them, who they can reach out to... So generally,
it's quite honestly, 'learn by doing.'" (IND-6)
Recalls - whether mock or real - can uncover
shortcomings in a company's recall systems, and when
followed by a postmortem, allow for a root cause analysis
and corrective actions. Measuring product recovery is one
way of analyzing recall effectiveness. Another is investing
resources into creating and maintaining "Key Lessons
Learned." This will allow the core recall team to reflect
on time: the time it took to gather together, to make a
decision, to implement the decision, and to complete the
recall. It will also encourage adjustments or additions to
be made to current plans and procedures.
Recall preparation involves keeping up-to-date documents
for recall plans, such as contact lists and drafts for public
communication. However, some participants from industry
(3 of 6) mentioned the challenge of changing roles, especially
when new members are introduced who lack knowledge and/
or experience. Not surprisingly, mock recalls may result in the
training or re-training of staff. Updating contact lists at a fixed
frequency and sending out supplier questionnaires may assist
with that challenge. Furthermore, it is vital to have back-ups
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Food Protection Trends May/June

for each core recall team member and to test those members
in mock recalls, ensuring that the necessary documents and
information are readily accessible to both the immediate and
back-up persons.
A point of reflection for some participants (2 of 6) was
that mock recalls typically do not include the notification
process (notifying regulatory bodies, suppliers, the public,
etc.). One suggestion was that the CFIA should consider
triggering unplanned mock recalls for industry, rather than
industry holding mock recalls when it chooses to, in order
to meet internal and customer requirements.
Risk assessment
A number of participants (3 of 9) expressed the belief
that there is a lack of transparency, among other issues, with
the Health Risk Assessments (HRAs) performed by Health
Canada. According to some industry interviewees (2 of 6),
the food manufacturer is not given access to the decisionmaking criteria or the algorithm that Health Canada uses
to perform its HRA. Furthermore, the participants (3 of 9)
feel that there needs to be more openness with regard to
how these risk assessments are performed. This could be
particularly important when the risk assessment performed
by Health Canada does not agree with that performed by
the company.
"I think the more openness [between government
and industry] there is on what each side has done
in regard to their own risk assessments and investigations, one - the more timely - and two, in some
cases, may actually limit the scope of the recall or
limit the need for a recall as well." (IND-3)
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