Updated: Jul 23, 2020
By Sarah Everhart
This is not a substitute for legal advice. See here for the site’s reposting policy.
Do you know how you would respond if your farm was found to be the source of a food safety emergency? While it is unpleasant to consider your farm’s products causing foodborne illness and/or being subject to a recall, taking the time to understand the process and plan ahead can be your best defense against the potentially significant legal and financial impacts of being the source of a foodborne illness outbreak.
To help producers through this process, the legal specialists at ALEI have created two easy to use on-farm recall planning resources: A Guide to Drafting A Model Recall Plan for Maryland Produce Growers and a Model Recall Plan. These resources walk producers through the process of identifying and planning for a food safety emergency. ALEI tackled this subject with help from experts at the Maryland Departments of Agriculture and Health, based on questions raised by farmers at annual food safety trainings.
A recall plan is a documented, systematic plan outlining how a grower will track and recall products. Plans can vary in specificity, but at a minimum a good recall plan should include the “who, what, and how.” In other words, who in the operation will do each task, what steps should be taken, and how will the recall procedures be implemented? Considering how your farm would respond to a recall raises important questions about the sufficiency of your farm’s records and food safety prevention protocols.
Although it may seem daunting, recall planning can be broken down into these ten steps:
1. Prepare for recall
2. Identify the concern
3. Initiate the recall
4. Notify the regulatory agencies
5. Identify and trace affected products
6. Notify affected parties
7. Control and dispose of recalled products
8. Determine the recall’s effectiveness
9. Terminate the recall
10. Remedy the recall’s cause and restore operations
Food safety emergencies can be financially devastating, not only for the farm or farms involved, but for the entire industry implicated in the outbreak. Farmers, therefore, will be well served to take the time this winter to consider planning how they would respond to a recall of their products.
ALEI Senior Legal Specialist Sarah Everhart will discuss recall planning at upcoming on-farm food safety and recall readiness workshops in January and during a series of webinars on food safety and recall readiness in February.