How to Prepare for a Food or Beverage RecallHow to Prepare for a Food or Beverage Recall

Essential steps to manage a recall, including safety and prevention, recall, and remediation, and the aftermath.

Kristen Kazarian, Managing Editor

December 6, 2024

11 Min Read
Five fundamentals of recall management
The five fundamentals of recall management include a strategic plan to better prepare you for a recall.zimmytws/iStock/Getty Images Plus via Getty Images

According to the Centers for Disease Control and Prevention (CDC), around 48 million Americans (one in six) are estimated to get sick from foodborne illnesses each year alone, caused by 31 identified pathogens, with approximately 3,000 deaths resulting from these illnesses.

A product recall can happen anytime for a variety of reasons: improper labeling due to not listing allergens, biological contamination due to various reasons, inclusion of foreign objects, and more. From safety to recall and remediation, here are prevention methods as well as tips on how to navigate through a recall if it does occur.

This article covers steps to protect yourself — and your business — from a recall including safety procedures, recall readiness, remediation, and the aftermath.

Former US Food & Drug Administration Deputy Commissioner Frank Yiannas, M.P.H., said in a LinkedIn post that conclusively determining the source of a foodborne outbreak relies on three critical pieces of corroborating information: 1) epidemiological data, 2) traceback information, and 3) ideally, microbiological evidence of the outbreak strain in food or the environment.

2024 Food & Beverage Recalls

In the third quarter of 2024 alone, the FDA recorded a 5.9% drop in recalls to 111 events and a 52.2% reduction in affected units to 4.62 million, according to a report by Sedgwick, a leading global provider of claims management, loss adjusting, and technology-enabled business solutions. In contrast, USDA recalls rose by half in Q3, with affected units surging by 5,366.7%, primarily due to the major Boar’s Head listeria recall. This increase marks the second-highest quarterly USDA total of affected units in more than five years.

Related:FDA Recall Update: December 2024

From January through October, there were 273 product recalls and public health alerts covering the food and beverage sector (including pet food) by the FDA.

According to the USDA’s Food Safety & Inspection Service, there were 47 meat, poultry, and egg recalls and public health alerts during the same period.

Following is a breakdown of the most recalls in the food & beverage sector overall, including pet food:

  • Mislabeling/Undeclared Allergens: 94

  • Biological Contamination

    • E. coli: 5

    • Listeria monocytogenes: 52

    • Salmonella: 24

  • Inclusion of foreign object – 9

  • High levels of lead – 8

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* Some listeria and salmonella events were part of larger recalls that included the product or ingredient listed, such as the following.

Largest Recalls of 2024

  1. Cinnamon (various brands) – due to high lead levels

  2. Boars Head deli & ready-to-eat meats for possible listeria contamination

  3. Milo’s Poultry Farms and Tony’s Fresh Market eggs – potential salmonella contamination

  4. Treehouse Foods frozen waffles, Belgian waffles, and pancakes (various brands) – possible listeria

  5. BrucePac Ready to Eat Meat Products (various products) – possible listeria contamination

  6. Taylor Farms slivered onions in McDonald’s Quarter Pounder hamburger, more – E. coli

Related:USDA Recall Report: December 2024

These recalls and outbreaks covered many states, included a variety of products, and led to consumer hospitalizations as well as some deaths.

The article “An Analysis of Food Recalls in the United States, 2002-2023” from December 2024’s Journal of Food Protection, shared a few facts.

Food and beverage recall events during that time period were due to:

  • Product contamination at 91% and processing issues at 9%.

  • 53% were Class I, 41% were Class II, and 6% were Class III

  • Biological contamination and allergens accounted for 96% of Class I recalls.

  • Listeria and salmonella together came in at 40% of all recalls

  • Allergens accounted for just over half (28%)

5 Fundamentals of Recall Management

To be well prepared for a recall and know what to do if your product does get recalled, you must have a strategic plan in place.

Sedgwick, a solutions provider for various industries and their needs — including product recalls and remediation — has outlined five fundamentals of recall management in its recent Recall 101 Webinar and Guide.

Related:Dog and Cat Food Brands Pull Products from Shelves

Fundamental 1: Recall readiness & strategic planning

For an effective recall response, create a structured plan rooted in Standard Operating Procedures (SOPs) that transcend boundaries and foster organizational alignment. Product safety professionals should use SOPs as a tactical roadmap, delineating specific roles and establishing clear channels of communication across legal, quality, compliance, risk, and public relations departments, etc. To help prepare, organizations should simulate real-world scenarios through frequent mock recalls.

Fundamental 2: Fencing the Scope

The first critical task in a recall is to precisely identify and isolate the affected products. This phase requires robust systems for real-time tracking, leveraging technologies such as barcode scanning, RFID, and ERP software to ensure accurate traceability of batch numbers, model codes, and serial numbers. By implementing well-defined processes that limit the scope to affected items, organizations optimize containment, protect resources, and minimize disruptions. Containing a recall’s impact extends beyond isolating affected stock; it requires a well-structured approach to reaching every affected stakeholder, including end consumers, intermediaries, and secondary markets.

Fundamental 3: Strategic Execution

Executing a recall demands a finely tuned approach that balances rapid response with meticulous planning. Each stage — notification, response management, and issue resolution—must be tailored to align with the product’s specific risk profile and the diverse needs of affected consumers. Consistent messaging via email, direct mail, social media, and dedicated recall microsites ensures that every stakeholder receives timely and accessible information. To further streamline communication, a dedicated recall hotline—separate from the main customer service line—can be a pivotal tool in alleviating pressure on existing operations. As companies work to engage and resolve recall cases effectively, they must also guard against fraudulent claims, especially on high-profile recall events.

Fundamental 4: Accountability

Documentation of recall actions is essential. From initial notifications to final remediations, every action should be systematically recorded, creating an irrefutable account of the recall’s course. By documenting each step, companies ensure alignment with legal standards and build a defensive record that stands up to scrutiny. Thorough documentation extends beyond regulatory fulfillment to serve as a cornerstone of internal transparency and accountability. Systematic archiving of recall records allows organizations to conduct retrospective analyses, drive databased process improvements, and ensure that each recall is a learning opportunity.

Fundamental 5: Event Close-Out

After the recall has closed, an extensive post-event audit is essential to verify that all affected products are effectively removed or corrected within all jurisdictions. Each regulatory landscape presents specific requirements for closing a recall, from environmentally responsible disposal protocols to item destruction or secure quarantining. To ensure regulatory compliance and safeguard against residual liability, companies should conduct market audits and validation checks post-recall. Effective close-out ensures that the brand emerges from the recall with credibility intact and all regulatory bases covered. As well, post-recall debriefs with representation from quality assurance, legal, communications, and operations teams, etc., offer a holistic view, enabling fine-tuning of procedures, communication strategies, and cross-departmental alignment.

Food Safety Inspections

With a six-year high for food recalls, what is happening with US food safety inspection and compliance? It isn’t that simple.

Food facilities are inspected by government agencies like the FDA and USDA’s FSIS through routine, risk-based inspections whereby inspectors visit the facility to assess compliance with food safety regulations, checking aspects like hygiene practices, temperature control, food handling procedures, and proper labeling.

The frequency of inspections depends on the facility's risk level, with higher risk facilities being inspected more often. Inspections can also be triggered by complaints or potential safety concerns.

“In my view, both the public and private sectors must get better at conducting root cause investigations, identifying the multi-dimensional factors (with more insightful granularity) that led to the recalls and outbreaks, and more articulately sharing ‘actionable lessons learned’ to prevent re-occurrences.” — Frank Yiannas, former FDA deputy commissioner

Companies also might have inhouse inspectors who perform daily pre-operational inspections, which can include verifying that shifts clean up, ensuring that equipment is calibrated and working properly, confirming that proper food sanitation procedures were followed.

The FDA has authority over food and beverages including dairy, seafood, produce, packaged foods, bottled water, and whole eggs, as well as pet food. USDA covers recalls for meat, poultry, and egg products. Dietary supplements are part of the food and beverage sector though fall under different regulations, which came from 1994’s Dietary Supplement Health and Education Act.

Food and beverage products go through rigorous testing and safety procedures, but there are various points in a product’s journey, including the farm/slaughterhouse, processing facility, packaging location, and the store shelf — as well as transportation when products come from other countries. At each of these points are workers handling the products, pieces of equipment being used, and materials that can come into contact with pathogens as well.

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Food is considered adulterated and subject to recall if it, the food, meets any of the following criteria:

1. If it contains a harmful substance and a potential food safety risk

2. If it contains an added harmful substance that cannot be reasonably avoided and exceeds permissible tolerance levels

3. If it includes a substance intentionally added to the food but not approved by a regulatory agency.”

4. If it has been handled under unsanitary conditions that may lead to contamination with substances that may pose safety threats

Both the USDA and FDA perform both routine and targeted inspections. The agencies also work with state and sometimes local agencies to inspect food facilities. The two agencies also work with the EPA to ensure regulatory compliance and food safety by sharing information and coordinating inspections.

Case Study: Boar’s Head

One of the widest recalls of the year was Boar’s Head ready-to-eat meat, deli, and poultry products in July. Ten people died and 49 were hospitalized across 19 states. There were 72 products in the recall including liverwurst, ham, bacon, bologna, pâté, head cheese, and salami, for a total of 7.2 million pounds.

This was the largest listeria outbreak since 2011, which was linked to whole cantaloupes from Jensen Farms’ Granada, CO, production fields. That outbreak caused 147 illnesses with 33 resulting in death.

Recall: What went wrong

A letter to USDA from 24 members of the US House of Representatives and three US Senators was published on Sept. 30, 2024. The letter refers to the released records outlining 69 major violations at the Jarrett facility that were documented over the year prior to the Boar’s Head listeria outbreak.

On October 15, the USDA launched an internal investigation into the listeria outbreak. Sen. Richard Blumenthal said that USDA Inspector General Phyllis Fong is looking into whether federal investigators and Virginia state inspectors responded appropriately to dozens of reports of problems at the factory. Inspection reports dating back at least two years indicated that the conditions could pose an “imminent threat” to food safety.

Some of the previous violations included meat buildup on equipment and floors and overspray on walls in the facility, blood puddles on the floor, rancid smell, bugs, mold, and standing water. It is possible for criminal charges to be forthcoming.

Based in Sarasota, FL, since 2001, the privately owned company was founded in 1905 in Brooklyn, NY, by Frank A. Brunckhorst. Currently, Boar’s Head Provisions is owned by the Brunckhorst and Bischoff families.

When the recall was issued, all production ceased at the Jarratt, VA, plant, where listeria was found. In September, two months after the recall, the plant was closed indefinitely.

Remediation: What they did right

Boar’s Head is working to gain consumer loyalty again, but it won’t be easy. Here are recent measures the company has taken in food safety and compliance:

  1. Closed plant that produced recalled products

  2. Stopped selling liverwurst, one of the main meats involved in the recall

  3. Hired former FDA Deputy Commissioner and food safety expert Frank Yiannas, M.P.H., who oversees the Boar's Head Food Safety Advisory Council

  4. Launched new website, boarshead.com/foodsafety, which offers:
    The company's food safety commitment
    The Boar's Head Food Safety Advisory Council
    The comprehensive food safety processes Boar's Head has in place for quality assurance
    Frequently asked questions about food safety at Boar's Head in the FAQ section

  5. Safety training for employees

  6. Ongoing third-party inspections to ensure compliance

  7. Safety training for employees

  8. Ongoing third-party inspections to ensure compliance

Boars_Head_closes_plant_that_had_Listeria_outbreak.jpg

Aftermath

A company statement reads, in part: "We want people to know more about the rigorous processes and procedures we have in place — with in-depth supplier vetting, monitoring, and audits; advanced technologies designed to uphold the highest safety standards; strict sanitation practices; comprehensive safety training for employees; certifications from leading food safety authorities; and ongoing third-party inspections to ensure constant compliance.”

But is it too little, too late? Most consumers already distrust food companies, with ultra-processed foods, food additives, and dyes becoming more apparent. Boar’s Head must work on their food safety program and keep consumers informed at all levels if they want to regain loyalty. This is not just a consumer issue for the company; it is a major financial loss as well.

Creating a strategic recall management plan is something every food and beverage company must commit to. As in the Boar’s Head case study, there were various violations prior to the Listeria outbreak at the Jarrett plant. In the end, the company had to scramble to create a remediation strategy in hopes of gaining customer loyalty. This could have been prevented with an overall plan, as discussed in the five fundamentals listed previously in this article.

Federal and state organizations are designed to assist manufacturers in terms of safety inspections, recalls, and remediation. Include a document in your plan that lists agencies and third parties that offer services in those areas. Learn from Boar’s Head: an outbreak is much more serious, time consuming, and costly than creating a plan with all necessary departments before a serious incident jeopardizes your consumer loyalty.

About the Author

Kristen Kazarian

Managing Editor

Kristen Kazarian has been a writer and editor for more than three decades. She has worked at several consumer magazines and B2B publications in the fields of food and beverage, packaging, processing, women's interest, local news, health and nutrition, fashion and beauty, automotive, and IT.

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