by Patricia Tripp, CFSA’s Local Produce Safety Manager
The process of conducting a mock recall in preparation for a GAP audit is one of the of the requirements for GAP certification, but many growers feel that performing a mock recall may be misunderstood by buyers. The fear is that buyers will mistake a mock recall for a true recall. Fortunately, this is an industry standard and the majority of wholesale buyers are accustomed to assisting growers with this exercise.
The purpose of this exercise is to test your recall plan in the event of an actual recall. While Good Agricultural Practices and Good Handling Practices cannot eliminate the possibility of a recall, it does assist with reducing risks. Growers that do everything right may still find themselves in a recall situation. Keep in mind that voluntary recalls in the produce industry occur on a regular basis. For example, someone can mislabel a broccoli for greens and may need to conduct a voluntary recall. A recall does not always occur strictly because of an immediate public health threat due to chemical, physical or microbial contamination.
A mock recall can be conducted within a few minutes and the effectiveness of the recall can be determined in seconds. The most time consuming step is likely getting in touch with your buyer and receiving confirmation from the buyer on what they have in stock. In your Food Safety Plan, your procedure will likely include a 2-4 hour window in which you are allowed to conduct this exercise. It is a short window because, in the case of a true recall, you will want to locate any affected product as quickly as possible to ensure that it is not being consumed by a customer.
You are only responsible for tracing the product one-step back to the field in which it was grown, and one step forward to the individual or company that purchased the product. It is the buyer’s responsibility to notify anyone they sold the product to upon receiving notification from you. Following the steps below will assist in simplifying the process.
Conducting a Mock Recall
Step 1: Determine the product and lot number that will be used for the mock recall.
Tip: Choose the customer that you have the best relationship with, to which you sell the most product, to conduct your mock recall.
Step 2: Determine the reason for the recall.
Tip: It is best to use a very low risk scenario for your mock recall. For example, I used mislabeling of product as an example above, or you could simply say that a rock was found in your product (physical contamination).
Step 3: Determine the quantities involved and the amount of product in the marketplace utilizing your traceability and inventory systems.
Tip: Invoices are the best place to access this information. The lot numbers should already be recorded on your invoices beside the product description as part of your traceability program. If you have not started recording these on all copies of the customer invoice, it is highly recommended that you begin this process immediately.
Step 4: Identify the customers who have received the product.
Tip: Again, invoices are the best place to access this information.
Step 5: Contact a customer that received this product by phone and explain to them that you are in the process of testing your traceability and recall systems by conducting a mock recall. Tell them that you will be sending a follow-up email that you need them to respond to.
Tip: If multiple customers received the same lot number, it is not necessary during the mock recall to contact them all, unless specifically required by the Standard you are certifying under. If you are unsure about the requirements, always cover your bases.
Step 6: Prepare an email to the customer you have chosen to conduct your mock recall with.
Tip: An example email is as follows:
As part of our food safety program, we conduct a fictitious (mock) recall on an annual basis as a requirement of our Good Agricultural Practices certification. We have chosen to recall lot number B1071617, 10# Broccoli, of which you received 4 cases. Please respond to this email letting me know how many cases you currently have in stock and how many have been sold.
It is important that you respond to this email as soon as possible. Our food safety program requires that we are able to trace all products within 2 hours. As mentioned previously, this is a mock recall; therefore you do not need to dispose of the product. Please distribute or consume the product as usual.
Thank you for assisting us with this exercise.
Step 7: Print confirmation email upon receipt from buyer. Complete any logs that are included in your Food Safety Manual. Attach the email to your Mock Recall Log and maintain with your recordkeeping.
And remember, mock recalls are often described in the industry as the most valuable practice a farm hopes to never have to actually use. By performing this exercise on an annual basis, you will always be prepared. Always utilize what you learn during this process to improve your traceability and recall systems.