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The Recall Plan must be written. It describes steps to take and assigns responsibility to do the following: • Notify direct customers and consignees, tell them what food is being recalled, and inform them how to return or dispose of the food. • Notify the public, when appropriate, about any hazard in the food, particularly in Class 1 and sometimes in Class 2 recalls (see sidebar p. 158). • Conduct effectiveness steps to make sure the recall was car- ried out. • Execute disposition of the food through reprocessing, rework- ing, diverting to a use that is not unsafe, or destroying it. The role of everybody in your company needs to be specified in advance so the recall can be conducted quickly and effectively. Building Your Recall Team You must define the roles of employees in relation to the recall. Although the owner or plant manager is ultimately responsible, he or she may not have an intimate knowledge of the production process. Therefore, you should identify a recall team and recall coordinator. The recall coordinator directs the recall team and organizes actions and communications that are taken. He or she must also make sure that all documentation related to the manufacture and shipment of the product is collected, including information such as ingredient batch sheets, laboratory testing records, and so on. He or she must also determine where the affected product is, and the quantity that may be unsafe, and report that information to senior management. Regulatory agencies also need to be notified. The recall team should also include various members of the staff, including production, shipping, sales and marketing, quality assurance, and so on. The training manual put together by the Food Safety Preventive Controls Alliance defines the roles of recall team members as follows: • Scope of recall • Regulatory agency communication • Recall initiation • Customer notification • Information and data compilation • Document gathering • Securing inventory of affected lots in your control • Product disposition • Documentation Because it is likely that some of the product has gone into com- merce, notification is an essential part of the plan and the procedure. You must contact the FDA, and its contact information must be in your written Recall Plan. Customers also need to be contacted immediately and unsafe product needs to be removed from com- merce. A press release must be issued to inform the public. Your written Recall Plan should have a template of that press release so it can be issued quickly. Recordkeeping and Lot Identification The Recall Plan starts with how accurately you keep records of ingredients coming into your facility and finished products moving out of the facility. Careful tracking of your products and identifica- tion of the sources of your ingredients will determine the effective- ness of a recall, and will impact on how much product you will need RECALL TEAM ROLES The recall template put together by the Food Safety Preventive Controls Alliance identifies the following individuals or responsibilities as part of the recall team: • Senior Operations Manager • Publicity and Public Relations • Sales and Marketing • Scientific Advisor • Logistics and Receiving • Quality Assurance • Accountant • Attorney • Administrative Support • FDA Recall Coordinator It is imperative to test the Recall Plan and recall team before an incident occurs. A Recall Plan is not something that is done once and put on a shelf hoping that it will never need to be used. It is a living document. 156 ❘ SPECIALTY FOOD MAGAZINE specialtyfood.com specialty food maker