Increased risk of recalls in European food sector – part 1

According to food safety expert Rob Kooijmans (, the number of serious issues reported by governments in Europe with regard to food more than quadrupled between 2008 and 2017. This strong increase indicates that the potential risk of an actual recall has increased correspondingly for European food producers. In this first article in a series of three, he discusses the most common challenges within companies when it comes to recall management, enriched with a number of anonymised practical examples.

Good preparation is half the job
Based on GFSI standards, the execution of a mock or test recall is mandatory at least once a year.
 Usually it means that the QA department of the company performs these independently and that's why it usually comes down to carrying out a traceability study with accompanying mass balance.

A good mock-recall however, is based on a realistic scenario, and is performed unannounced. At the same time, the management team and/or the crisis team are also actively involved during the mock-recall. This immediately tests whether absence and replacement by relevant persons is also well organized. After all, recalls do not fit neatly into the agenda and usually occur at four o'clock on the Friday afternoon.

A good example of a realistic mock-recall concerns an industrial bakery. During internal audits, the QA manager noticed that FIFO was not being used to process the stock of flour. The flour was randomly dosed from one of the three silos present on site, depending on the operator judgement. As a result, with every delivery of a full truck with new flour, the contents of the truck were emptied into two and sometimes even three silos. During the mock-recall, the QA manager chose a scenario in which a supply of flour appeared to be contaminated with e-coli. Because the flour was not processed first in first out (FIFO) from the silos, at the end of the day - during the evaluation of the mock-recall, it became clear that the amount of product to be recalled was very large. After analysis, it appeared to be six times more than would have been necessary if working in a FIFO manner. Based on this mock-recall, the management of the company immediately decided to start working with in a FIFO manner the flour silos.

Early detection and recognition of problems
Within a lot of companies all complaints and internal blocked stock issues are treated as equal and processed one at a time. This way of working might cause a food safety-related complaint to remain uninvestigated a few days before being picked up. This is a risk, because late investigation of the complaint, the issue in the market can become greater and valuable time has been lost during which the consequences still might have been limited. For producers of ingredients for the food industry, this risk is even greater because other products are made with their products.

For example, an issue with, for example, rennet for cheese can lead to tons of contaminated cheese, and next to this a similar amount of contaminated whey powder. This whey powder can then be used again in baby milk and other foods, thus adding many tons of (secondary and tertiary) product the recall. In this way the possible costs of a recall can be increased by a factor of 100 to even 1000 compared to the market value of the contaminated raw material.

A crucial aspect in recall management is therefore the quick and effective investigation and treatment of food safety issues both within the company and in complaints coming in from customers and / or consumers. An issue concerning food safety must in principle be investigated and evaluated in detail the same day to avoid delaying the issue.

The department that receives complaints from customers and / or consumers must be well trained in the identification of food safety issues and next to this also in asking for details that may be relevant in the assessment of the issue such as the lot code and product best before date, how much of the product has been consumed and when, what the disease symptoms are, when these have occurred, etc.