Posted: May 2003
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Article SummaryThis is a pretty good overview of various expert opinions (including mine) on how food companies should behave after a recall.

Restocking the Shelves:
Recovering from a Recall

Food Quality, June/July, 1999

Today it is common to see announcements of food and beverage recalls on the nightly news, usually with great attention paid to contaminants, pathogens and possible victims. But often, coverage stops with the last returned package, with little attention to how a company recovers and improves itself after a recall. This article examines how three companies changed their QA programs in response to a recall, and looks at strategies to prevent contamination incidents before they occur and to deal with them once they do.

Bil Mar, Hormel, Hudson, IBP, Odwalla, Oscar Meyer, Thorn Apple Valley and Winn-Dixie. These companies have a lot in common: they are some of the largest, most profitable and well-known food and beverage producers in the US. And they have all been hit with a product recall as a result of pathogen contamination – most of them within the past year.

While dramatic outbreaks have brought the issue of foodborne illness to the forefront, public health and food safety officials agree that most foodborne illnesses occur as isolated cases, not as part of publicized outbreaks. This judgement was supported by a 1996 Government Accounting Office (GAO) report which compiled data from various agencies and departments, including USDA and FDA.

Just compare the numbers: as a result of the contamination incidents associated with these eight companies, there have been more than 150 reported illnesses and at least 20 related deaths, with some of the recalls having no illnesses associated with them at all. But each year between 6.5 and 81 million cases of foodborne illness and about 9,100 related deaths occur, according to estimates of research completed over the past 10 years. (For more on these estimates see Nov./Dec. 1998 FQ, p. 34).

So why do these recalls continue to make headlines across the country? Many experts believe that with emerging new pathogens and increasingly elusive old ones, contaminations and foodborne illnesses are simply occurring more often. According to the GAO report, many public health officials believe that the risk of foodborne illnesses has been increasing over the last 20 years. Increased vigilance on the part of the food industry and better surveillance on the part of health authorities are probably also ensuring that fewer incidents escape our attention.

“In general, recalls are occurring more frequently,” says Pat Kendall, Ph.D., R.D., Professor in Colorado State University’s Department of Food Science and Human Nutrition in Fort Collins, CO. “If you take a look at the Tylenol tampering incident of some years ago, it was in the news all by itself. But within the past year, there have been at least three big ones that have been covered in the media.”

“Triple Clean” Beef

One company that made modest headlines in the past year and a half, IBP of Dakota Dunes, SD, began to beef up its QA measures even before being hit with two separate voluntary recalls at different facilities. In April 1998, IBP recalled more than 250,000 lbs. of ground beef produced at its Joslin, IL, plant due to E. coli O157:H7 contamination. Four months later, IBP, the world’s largest producer of fresh beef, recalled more than 500,000 lbs. of ground beef from its Dakota City facility on account of the same pathogen. No illnesses were reported as a result of either incident.

“We have long realized we can’t be successful without excellence in food safety and product quality,” says Gary Mickelson, Manager of Communications for IBP, which started a toll-free hotline and a website for concerned customers immediately after the recall. “We have committed $100 million in capital expenditures and increased operating costs over the past five years – specifically to improve food safety and quality in our fresh meat plants, including the development of a food safety process for beef called ‘Triple Clean.’”

Triple Clean, a procedure that involves a series of processes applied to each beef carcass, uses vacuums, carcass wash and organic acid rinse systems, and steam pasteurization cabinets. The system, and its scientifically proven multiple-hurdle approach, is supported by leading government and university researchers as the most effective way to reduce or eliminate unwanted bacteria from beef carcasses, Mickelson says.

As the first step in the Triple Clean process, IBP uses a combination of traditional knife trimming and steam vacuums, located at sites on the carcass production floor, where contamination potential is the greatest, to clean and sanitize carcass surfaces. The vacuums, which IBP helped develop, operate much like a carpet cleaner: steam is spot applied to carcass surfaces, and then the vacuum removes contamination and condensed moisture, immediately sanitizing surfaces.

“The steam vacuum was one of the first significant high-tech microbial tools developed as a result of the emergence of E. coli O157:H7 as a dangerous food pathogen in the early 1990s,” Mickelson says. “It is very effective in the hygienic removal of contaminants from the carcass surface.”

The second step in this process is the carcass wash and organic acid rinse treatment. After hide removal the carcass is completely washed and then rinsed using USDA-approved, bacteria-killing, organic acids. An additional organic acid rinse provides a significant kill step for any surface bacteria that remain on the surface. “Research shows that the hide removal process is more likely to cause contamination of the carcass than any other production step,” he says. “Using a carcass spray immediately after the hide is taken off removes bacteria before they can attach to the carcass surface and start growing.”

After final USDA inspection, each carcass passes through one last wash specifically designed to apply a high-volume, low-pressure water wash over the entire carcass surface, thus removing small particles, such as bone dust and blood, from the carcass surface. After this final wash, each carcass passes through the steam pasteurization cabinet where it is blanketed with pressurized steam, the third step of the process. As the carcass exits the cabinet, a cold water rinse quickly reduces the surface temperature. Then the carcass is again treated with an organic acid rinse, of either lactic or acetic acid.

“This second 1-2 punch of steam and organic acid carcass treatment puts the final food safety touch on the carcass,” Mickelson says. “Both of these treatments [steam pasteurization and organic acid] are effective, stand-alone interventions individually. The combination of the two is the most-significant microbiological intervention treatment, outside of radiation, that can be applied to the beef carcass for maximum food safety assurance.”

To validate the effectiveness of the Triple Clean system, IBP, which employees more than 700 full-time workers solely dedicated to product safety and quality, utilizes a microbiological testing regime wherein carcass and meat samples are tested daily to assess process control and product quality. IBP’s microbiological testing programs are supported by 12 on-site, fully accredited laboratories.

QA personnel also inspect carcasses during skinning and evisceration to determine the effectiveness of each process, while each site that may be affected by hide removal or evisceration is evaluated for potential contamination.

In addition to the Triple Clean process, IBP employs vigorous Hazard Analysis Critical Control Point (HACCP) programs in each plant, as well as other quality control programs, Good Manufacturing Practices and Standard Operating Procedures. The company’s food safety assurance systems include pre-operation sanitation, carcass production and product temperature audits, employee training, packaging system audits and temperature verification on shipping trailers.

“Our commitment to food safety also includes efforts to develop new food safety technologies, such as ‘electronic pasteurization,’ pre-harvest treatments for the control of pathogens and improved sanitation technologies,” he says. “We are working with livestock producers to determine what factors in feedlots or on farms and ranches contribute to the presence of pathogenic bacteria in or on animals. We also support research and development for better testing of bacteria on carcass surfaces or in the final meat product.”

After The Storm

Even though the contamination sites have not been discovered at either facility, IBP is looking into the possibility of using irradiation or pasteurization to improve their QA programs, as well as continue to implement Triple Clean in all of the company’s fresh meat operations. IBP, which purchased the Columbus, NE, meat processing facility formerly involved in Hudson Foods’ recall of 25 million lbs. of beef, is one of several meat processors that has an agreement with Titan Corp., which is developing an electron-beam pasteurization facility in northwest Iowa, to provide meat pasteurization services, Mickelson says.

Besides finding new ways to improve the production at their facilities, IBP has begun producing more case-ready ground beef for retail stores. Producing case-ready product makes less work for the retailer because they do not have to grind or package the meat, says Mickelson, and since the product reaches the consumer with less handling, another selling point is safety. This is somewhat of a change for the company, which deals mainly with other meat processing companies and foodservice operations. Most consumers are not familiar with the IBP name, since they do not currently produce many branded products for the retail food industry.

Despite two recalls in the same year, IBP’s 1998 earnings were the second best in company history, Mickelson says, and the company’s penetration into the booming foodservice market and a strong performance by its fresh meat operations were the biggest boosts. “Our customers, for the most part, were very supportive and cooperative in the recall effort and aftermath,” he says. “But many of them are very frustrated and confused by USDA’s position on E. coli O157:H7 as a pathogen in fresh meats and the related testing programs USDA has imposed. The impact of the flurry of recalls in the industry has caused severe financial problems for several firms ’ both large and small. Some have even gone out of business.”

Bring In The Experts

Like IBP, Bil Mar, and its parent company, Sara Lee Corp. of Chicago, has been able to regain most of its market despite their voluntary recall of 15 million lbs. of hot dogs and packaged meat products last December. The recall, due to Listeria contamination found in some product, cost Sara Lee $76 million, and was linked to 73 illnesses and six deaths.

The recalled brands, such as Ball Park, Bil Mar, HyGrade, Mr. Turkey and Sara Lee Deli Meat, have seen some negative impact from the recall, but data has shown recently that the company’s share in the hot dog market has surpassed pre-recall levels, says Jeffrey Smith, Director of Media Relations for Sara Lee. “In addition Sara Lee deli meat products are back in more than 80% of the retail outlets that carried them before the recall,” he says. “We believe this is an outstanding success rate considering we are only five months out of the recall. We think the consumer respects and appreciates that we voluntarily recalled the product and that action was taken even before any conclusive data was available.”

As Sara Lee’s market share continues to grow, so does the uncertainty of the source of contamination at the Zeeland, MI, plant. In March, the Centers for Disease Control and Prevention (CDC) reported that dust from construction work in a plant air conditioning system may have been the culprit of the Listeria contamination (see March 1999 FQ, p. 13). But the source has not been confirmed and CDC’s recent report stated its uncertainty of the source of Listeria. “As we see it, that uncertainty continues,” Smith says.

Because of this uncertainty, Sara Lee has taken a range of actions to recover from its contamination incident. A new procedure, reheating packaged meat, was added to the HACCP program at the Zeeland plant. Quite simply, the meat is reheated to a certain temperature to eliminate any low-temperature pathogens. As always, Sara Lee tests its product and holds it before shipping it to customers. “Other changes have been made to our HACCP program and overall measures, and these changes were developed with the oversight of USDA,” Smith says. “However, the specifics of our HACCP plan remain confidential.”

The Zeeland plant, which reopened in March, currently only produces bulk lunch meat to be sliced and sold at deli counters under the Sara Lee name. Retail hot dog and sliced deli products are being reconfigured, a process which will take about six to nine months to complete, Smith says.

Sara Lee, which also started a toll-free hotline and added information about the recall to its corporate and brand websites shortly after the recall began, brought in experts as part of its product reconfiguration to take a look at protocols and help implement new technology, including environmental and product testing, specially controlled environments for production and packaging, and new packaging with additional preparation instructions for customers.

“We have worked closely with government agencies to facilitate their investigations,” said C. Steven McMillian, President of Sara Lee, in a prepared statement. “And now, having consulted outside experts in assessing and developing state-of-the-art food safety practices, we are embarking on a multi-year, $100 million-plus program to implement new processing, cleaning and testing procedures that exceed current industry-wide practices.”

In May, Ann Marie McNamara, Ph.D., former Director of the Microbiology Division of USDA’s Office of Public Health and Science in FSIS, joined the parent company as its Vice President of Food Safety and Technology. During her seven years at USDA, McNamara served as the agency’s representative to President Clinton’s Food Safety Initiative and on USDA’s committee responsible for drafting HACCP rules.

Sara Lee has also donated $1 million to the Georgetown Center for Food and Nutrition Policy to fund applied research projects, including studies of post-processing bacteria elimination, or "post-pasteurization," and potential food additives. The fund set up by the university has a website and phone number so scientists and the public can submit grant proposals.

Send In The Team

Like Sara Lee, Odwalla of Half Moon Bay, CA, also took active steps outside the production facility to increase QA measures after a voluntary recall placed them in the limelight. In 1996, about 70 people became ill and one child died from E. coli O157:H7 linked to Odwalla’s unpasteurized apple juice. The company recalled all apple juice and all juices containing it, as well as carrot juice and vegetable juice.

As a result, Odwalla developed the Nourishment and Food Safety Advisory Council as a means for the company to get expert advice on QA and food safety issues. “We needed a group of food safety experts to give us scientific-based facts so we could move forward after the recall,” says Linda Frelka, Vice President of Quality Assurance for Odwalla, which also set up a website and toll-free number after the recall. “The council, which still exists, also advised us on how to correct a process to make sure it was safe.”

Besides the council of experts, the outbreak also lead to the development of a HACCP program for Odwalla’s facilities, including the plant in Dinuba, CA, where the contamination is suspected to have occurred even though no E. coli was found there.

As part of its plan, Odwalla instituted seven critical control points (CCPs) to reduce the number of microbes in product. Flash pasteurization, the first CCP, is a high-temperature, short-time pasteurization used for juice such as apple, carrot and ginger. “Flash pasteurization is used for any product or ingredient that has an exterior that can’t be thoroughly cleaned or if the skin is actually used in juice,” Frelka says. “This process has tremendously improved product shelf life.”

Besides flash pasteurization, other CCPs include certificate of analysis program for all incoming ingredients; sanitation of fruit and monitoring the concentration of chlorine; examination of fruit for defects on the receiving line after the first washing; observation of the second sanitation of the fruit prior to extraction; and the involvement of a filter and magnet in the filling/bottling process.

Despite the fact that the actual source of the contamination has not been found, Odwalla has been able to remain competitive in the fresh juice industry by restructuring its sales and distribution departments, taking the lead on juice food safety and launching new products. “We are always trying to develop new products that stay on the cutting edge of consumer nourishment,” Frelka says. “But the consumers have not forgotten what happened and perhaps they never will.”

Learn From Experience

While IBP, Sara Lee and Odwalla have done more than just survive their voluntary recalls, the industry can learn a great deal from these incidents and others like them. Just as each HACCP program is built around both general food safety principals and individual characteristics of plants, processes and companies, so is a recall strategy dependent upon both received wisdom and attentiveness to particular details in how it plays out for the public.

“Some companies, such as Odwalla, have done really well with recalls,” Kendall says. “Odwalla created a website with a message from the company president on it that showed concern and that they were able to take the necessary steps to prevent further incidents. It was all very responsive and consumers looked upon it very favorably.

“Before the recall, Odwalla was known as a health-conscious and environmentally sound company, and they still are,” she says. “It seems they ran into problems trying to keep up with consumer demand.”

IBP also took the proper steps in getting out the message, and showing their concern and their ability to take the necessary steps to contain the problem and prevent further incidents, Kendall says.

“Sara Lee hasn’t played out yet. Since the contamination appears to be related to the air-conditioning system, I don’t know how it will play out in consumers’ minds,” Kendall continues. “It almost looks as if the contamination was beyond Sara Lee’s control. You don’t see this recall in the media as much as you might expect considering the relatively high number of deaths involved. It could be the number of news stories taking place at the same time. If nothing else is happening, a recall will probably get more play compared to when it’s up against news of a Presidential scandal.”

While the merits and downfalls of IBP, Sara Lee and Odwalla seem to be passing concerns, other recalls stick in the minds of consumers and industry alike. For example, circumstances surrounding the 1993 Jack in the Box contamination, in which 600 people were made ill and three people died from E. coli infection, have often served as poignant reminders for both industry and consumers.

“There are two problems with handling a recall,” says Peter Sandman, Ph.D., risk communicator based in Newton, MA. “One is getting the recall to work right: getting the word out to wholesalers, retailers and customers; getting it clear which lots are involved; and getting the stuff back. The other is managing the company’s reputation with consumers.

“The two are related, of course. But it’s possible to handle one well and the other badly. Jack in the Box screwed them both up. Their trouble was getting the information out quickly and to enough places. They ended up chasing the contaminated product; it wasn’t just in Washington state.”

A company has to walk a fine line between saying problems are worse than they really are, which does some damage to the company’s reputation, says Sandman, and announcing that a situation is better than it actually is and then having to go back to say it’s worse than they thought, which does much more damage to reputation. Sandman, who works extensively with the oil, chemical and mining industries, has advised approximately six food companies on various problems, including meat recalls.

“Ideally, you want to make an estimate as small as you can make it such that you can guarantee it will not be worse than that,” he says. “That’s how bad you say it is. You do this with qualifiers, of course: we very much hope it’s better than this; we hope it turns out smaller than this, but to be sure…”

The second mistake often made in the industry, and which Jack in the Box committed as well, is scapegoating by looking for someone to blame other than yourself, Sandman says. In almost every crisis there are any number of people or institutions which may bear some responsibility for the incident, he says, and if any one group did a better job, there would be no need for a recall. “Jack in the Box could have accurately said, ‘If we were not given tainted meat…,’” Sandman says. “And the slaughter house could have accurately stated, ‘If Jack in the Box cooked the meat hot enough …’ These two statements are absolutely true and this situation is normal. There is great temptation to blame the other party. It’s overwhelming.”

But inflicting harm on the other parties involved will also cause damage to your own company. The public’s reaction will be “a plague on both your houses,” says Sandman, “and there’s evidence and research that supports this.”

“Companies have to admit responsibility when it comes to a contamination,” says Denis Stearns, a partner in Marler Clark, a law firm located in Seattle that handles many foodborne illness cases. “Lawyers have a tendency to dissuade the company from admitting fault because of liability. But there’s no question that you’re liable if people became sick or died from your product.

“With Jack in the Box, they agreed to pay all medical bills without question even before the cases were settled. This proved to generate a lot of good will with people,” says Stearns, who along with fellow partner Bruce Clark, handled the cases for Jack in the Box’s parent company, Foodmaker, during the foodborne illness incident; William Marler, another partner, was the lawyer for a girl who became ill as a result of the contamination and received one of the largest settlements in Washington state’s history from Foodmaker.

“In some cases, lawyers go to the hospital and ask patients to sign releases before treatment will be paid for by the company,” Sandman says. “It really looks bad to play corporate interest against a poor kid who is lying in the hospital. The public will see it as the company did something wrong and is not sorry for it. For the victims, this sort of company action becomes a source of outrage. Some people may or may not sue a company that has made them sick. But as soon as the company does something selfish, the victims get angry as well as devastated. An angry victim can do enormous harm to a reputation in the media.”

To combat this problem, the legal and public relations sides of a recall should be blended, suggests Stearns, whose practice also consults companies on how to prevent and handle recalls, and holds seminars for the public on how to properly avoid getting sick from a pathogen. Lawyers make companies seem defensive, but the quicker a company puts the recall behind them, the quicker they get on with business, he says. When insurance companies get involved in the cases, it can take much longer to settle, he says, mainly because companies leave it in the hands of the insurance companies who do not want to pay, so they allow the case to drag on.

“If they are not feeling pressure from the companies, it can go on forever,” Stearns says. “And defense attorneys get paid by the hour, so they’re not exactly in a hurry to get it done with either. Jack in the Box leaned on their insurance company and told them that they didn’t care how much it cost, they just wanted to get it over with and put the entire incident behind them and move on.”

Jack in the Box took about four years to settle because of the large number of claims, Stearns says, but in general, a regular food case can be resolved in a year.

Another mistake companies often make when faced with a recall, is that they and their executives have a tendency to hide their emotions, Sandman says. “What happens often in a crisis is that the company is so interested in demonstrating that they are competent, they forget to demonstrate their humanity,” he says. “They should focus more on how upset and devastated they are rather than demonstrating their competency.”

Concentrating on the legal or technical side of a recall is another mis-step often committed in the industry, Sandman says. Companies tend to get narrow advice from either the legal or technical experts who are more concerned with those specific aspects of a situation rather than the company’s reputation, he says, but most contamination incidents cause more harm through damaged reputations than they do through huge monetary damages. “Part of the problem is that many public relations people don’t understand risk communication,” he continued. “Most of the time consumers are inattentive and credulous, and public relations people have to grab their attention. They become skilled in creating sound bites and know what to shove down the throats of consumers. But during a recall things are different, the public is attentive and hostile, almost to the point where they think you are the anti-Christ” and the usual simplistic sound-bite strategy may have disastrous consequences.

Proactive vs Reactive

While state-of-the-art HACCP programs and recall strategies may be the cornerstone of a successful food or beverage producer, deeper changes may be necessary inside homes and minds, rather than in plants, to really reduce foodborne illness.

To do so companies need to deal with risk communications rather than crisis communications, Sandman says. “It’s more about how to deal with issues over time, especially relationships with stakeholders, the media and the public, and about what might go wrong rather than what did just go wrong,” he says. “Companies do need crisis management strategies in case of a terrible event, but in the meantime, they need to talk with people about how meat is not a ’virgin’ product and really educate consumers.”

Kendall adds, “I don’t think consumers have a realistic view of how food is processed. Consumers need to better understand farm-to-table process so they see food as a living organism. Right now, people think milk comes from containers and meat comes in a box.”

Copyright © 1999 by Food Quality

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