PET Food Processing - March 2020 - 28

FOOD SAFETY

"Take the time before a recall occurs
to consider your organization's own
capabilities and messaging."
Dana Brooks, Pet Food Institute
Mitchell emphasizes the importance to notify distributors and other stakeholders early in the process so
they hear the information directly from the processor
and not from competitors, the media or regulators. "This
assures that the supply chain has accurate, timely information and allows processors to define the issue on their
own terms," she adds.
Billie Johnson, Ph.D., food safety and regulatory
compliance manager, BHJ North America, Omaha,
Nebraska, says having a validated program in place is
key to dealing with a recall. "What I mean here is repeatedly testing the full process to ensure a true recall program is in place and fully functional," she says. "Many
companies say they have a recall policy but have never
truly tested it before being in a real recall. Being in a recall is not the time to find out the program is flawed."
Mock traceability exercises are good but fully testing
the ability to assemble the recall team and understanding where weaknesses lie is very important to creating
a good program, Johnson adds. Many recalls can be
prevented by having the appropriate equipment, solid
monitoring techniques, training and policies in place,
she says. "Third-party food safety audits are a means to
verify programs are in place and that drills have been
conducted to ensure the recall plan works," she adds.
Adam Stroh, process project manager for Stellar,
Jacksonville, Florida, says there are two main things pet
food processors must do to be prepared for a recall. First,
they should always properly document the quality control
checks for their processes, ideally at 15-minute intervals.
Second, they should establish a company-wide hazard
analysis critical control point (HACCP) plan, which
notes HACCPs such as x-ray, metal detection and vision
systems, to name a few, he says.
Processors should also establish good manufacturing

PET FOOD PROCESSING | March 2020 | www.petfoodprocessing.net

practices (GMPs) for how the company approaches its
process. "If and when a recall is suspected, paperwork
from the window of time in question would be pulled
and documentation from that process showing acceptable checks would help narrow down any questionable
product that's been released," Stroh says. "Response time
will vary depending on where the product in question is
at the time of the incident."
Additionally, he says proper training of plant personnel is a key aspect to minimizing product recalls. "All
employees should be aware of the company's expectations and be instructed to report an issue if they see
one," Stroh says. "If the whole team is aware of these
standards and is motivated to perform their jobs properly as a team, it will greatly reduce the possibility of a
product recall." Above all else, Stroh emphasizes the
importance of documentation, documentation and
more documentation.

Potential causes of recalls
Brooks says it's important for companies to remember
that recalls can happen for a variety of reasons thanks to
an evolving regulatory landscape and engaged shopper
base, and this can impact how pet food makers weigh
possible scenarios. "For example, a pet food maker's
internal monitoring program may identify an out-ofspecification step in the manufacturing process that can
lead to an issue, such as a mislabeled product or ingredient imbalance," she says.
As the internal systems trigger a concern, pet food
makers can voluntarily recall a product. "Otherwise,
Above: Recall preparedness includes testing for causes such as
foreign material contamination to ensure the plan is functional.
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PET Food Processing - March 2020

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