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to take off the market. This ultimately influences the reputation of your company and the bottom line. Identifying the lots in a specified manner is essential. Badly identified lots hinder the recall and can lead to either more of the unsafe product getting onto the market or more product being recalled than is necessary, both bad for business. Multiple people within your organization should check information sources to ensure recordkeeping is accurate. The FDA and possibly state and local agencies will carefully review these records. Effectiveness checks need to be a part of your Recall Plan. These will verify that everybody who might have received the prod- uct has been notified and that they are taking action. You will need to contact consignees via phone calls or email every day while the recall is progressing to make sure that all product is taken off the market. Your Recall Plan should include scripts for the phone calls and templates for the emails so that you are prepared. The Recall Plan should also specify anticipated procedures after a product is recalled; i.e. will it be reworked, possibly repo- sitioned for animal feed, or destroyed? You need to account for all product involved and what has ultimately been done with it. Recalls and Your Food Safety Plan If you have a recall, you will need to review and possibly change the written Food Safety Plan that is required as part of the Preventive Controls for Human Food regulation. You must write down all the decisions that were made during the recall, and whether they were effective. Your Food Safety Plan itself might be fine, but you may discover a need for more training or better equipment that may have caused the unsafe food. It is imperative to test the Recall Plan and recall team before an incident occurs. You need to verify and update information, such as supplier lists and customer lists and make sure the recall team is up to date based on who is currently employed. 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. Ron Tanner is vice president, philanthropy, government, and industry relations for the Specialty Food Association. NOTIFICATION PLANS In its recall template, The Food Safety Preventive Controls Alliance includes instructions for how consignees should be notified. You will find information on the following: • How letters will be sent to customers (i.e. overnight mail, certified mail) • Draft phone script • Draft recall notification for website and instructions for posting it • Draft instructions for consignees on what to do with recalled product. (FDA will want a copy of the final instructions.) The Recall Plan should specify anticipated procedures after a product is recalled; i.e. will it be reworked, possibly repositioned for animal feed, or destroyed? You need to account for all product involved and what has ultimately been done with it. RECALL TYPES FSMA gives FDA the authority to demand a recall. And it will do that for all Class 1 and some Class 2 recalls. The types of recalls are: • Class 1 Recall: Reasonable probability of serious adverse health consequences or death • Class 2 Recall: May cause temporary or medically irreversible adverse health consequences • Class 3 Recall: Not likely to cause adverse health consequences 158 ❘ SPECIALTY FOOD MAGAZINE specialtyfood.com specialty food maker