An estimated one in 10 produce companies has a plan that enables it to make strategic decisions, protect the company’s reputation and minimize its liability during a recall.

Produce recall plans vary with company size, product diversity, supply chain complexity, and even leadership style. Regardless of how long or short, detailed or general the recall plan, it should do these six things:

Start with the decision-making process

Companies in a potential recall situation must make critical business decisions in the first 24 hours, so include the decision-making process in the recall plan. This process includes collecting as much information as possible.

In the plan, identify specific questions to ask about how the problem was detected, labs sheet analyses, sampling methods and product identification, just to mention a few. Also identify in the plan those who will be involved in the decision-making process and the various factors that should be considered, such as public health, regulatory stipulations, legal liability, reputation and brand value. The company can be strategic and deliberate in its actions if it plans for the decision-making process.

Integrate technical and communication functions

While it may be tempting to maintain separate food-safety and crisis-communication plans, because these functions must work so very closely together during a recall, they should be integrated.

In each plan, identify the areas where the food-safety manager and the communication person will need to work together, for example when developing technical talking points about the company’s food-safety systems.

Also, reference the relative timing of the various activities. For example, reference that the initial customer communication can be issued before the root cause analysis.

Finally, ensure that the crisis communicator and the food-safety manager have direct contact so that the information that is being communicated is always current and technically accurate.

Designate an overall leader

Often times the food-safety or quality-assurance manager is designated as the recall team lead. If recalls were only about food safety, that would be fine. But they aren’t.

Recalls are an amalgamation of food safety, communications, customer service, insurance processes, legal strategies, consumer relations and more. It is extremely difficult for the food-safety manager to implement the technical part of the plan and also oversee all the other aspects of a recall. In fact, it is difficult for any one person to both implement and oversee the many recall activities.

Ideally, one person, typically a senior manager with decision-making authority, is the recall team lead. Having this single point of strategic leadership frees up food-safety manager to oversee the technical execution and regulatory compliance, and another person to oversee the communication and administrative activities. This other person may be a marketing, sales or human resources manager, depending on company resources.

Identify implementation resources

It is critical that your recall plan not only identify the tasks that must be carried out, but also who will carry them out and how. For example, a plan that lists “develop the consignee list for FDA” as a necessary task should specify the sales, accounting and production information that will be included in the list.

In addition, it should identify the staff responsible for collecting the information, and determine ahead of time if a current company report can be used to compile the information or whether a new report must be created.

Likewise, simply listing “answering consumer calls” as a necessary recall task is too vague. The plan should identify who will talk to consumers about the situation, and when and how will they be trained to have those conversations. The plan should clearly show how calls will be routed within the company.

After making a list of what needs to done before, during and after a recall, think beyond that and plan for the execution as well.

Include all phases of the communication process

The communication section of the plan should be more than a series of templates. It is important to include the complete communication process, which includes drafting, approving, training and disseminating the messages. Identify who will draft the communication messages and documents and who will approve them. One person should be authorized to approve all communications; this will help to keep the messages consistent.

The plan should also identify who will deliver the communication messages or documents to customers, consumers and other audiences. Finally, the plan should recognize that these people will need to be trained on how to use talking points and answer questions.

Account for regular training and testing

Finally, it is good to include a “last updated” date on the cover or first page of the recall plan, but it is also important to identify who is responsible for updating the plan. Accountability is key to maintaining the company’s preparedness level.

In addition, add a “last training date” and be sure to train new employees and refresh the skills of others. In conjunction with the training, test the plan and the company’s ability to execute it every 12 to 16 months.

Remember, testing the plan should be more than a traceability exercise; determine scope, practice asking questions and answering hypothetical regulatory questions, and draft communication documents and reply to mock consumer questions.

For more tips on what to include in a produce recall plan, visit the Sample Recall Plan Checklist on the United Fresh Recall Ready webpage http://unitedfresh.org/assets/RRChecklistFinal.pdf

Amy Philpott is an accredited public relations professional and the senior director at Watson Green LLC, a public communications firm in Washington, DC, specializing in issue management and risk communications. She assists produce companies develop, implement and evaluate crisis management plans, recall training programs and reputation management strategies. Amy will be speaking on Thursday, June 12 at 11:30am in the Fresh Tech Hall at the United Fresh Produce Show in Chicago.