One month after leaving FDA, I was asked to advise a company that was about to undergo a food recall for the first time.
In my tenure at the Food and Drug Administration, leading communications for the foods program, I was usually involved in recalls tied to major outbreaks or to complex, potentially high-risk food safety situations that were proving difficult to address quickly. These recalls were the ones that generated a lot of media coverage, Congressional interest, and consumer concern.
But, these recalls were — and are — the exceptions.
Most food recalls are not linked to illnesses and are relatively straightforward. And that was the case with the recall I was being asked to advise on.
That said, even the most routine recall, can be challenging for a firm. So, in my first conversation with the CEO, we talked about how to undertake a recall that would protect the public, the brand, and the firm. I emphasized the need to act promptly, put consumers’ health first, and work closely and cooperatively with FDA.
He agreed, and we quickly got to work. When he asked me to prepare the press release announcing the recall, I informed him that FDA actually posts model press releases on its website for industry to use. They’ve developed models for recalls related to allergen alerts, Clostridium botulinim, Listeria monocytogenes, Salmonella, and E-coli 0157:H7. I sent him the link and his staff used it to draft the release. I advise any firm to do the same rather than paying consultants to draft their own releases!
After reviewing the press release the firm pulled together using the model release, I urged them to include photographs of the products. The FDA recall coordinator later confirmed that the agency considers photographs to be an important way to help consumers know which products are recalled. The agency posts online its cadre of experienced food recall coordinators alongside the states for which each coordinator oversees.
I also advised him to post the press release on the company’s website and explained that FDA does not prescribe how and where to post the information but rather states that “it should ensure that the warning is prominently displayed and accessible from both its home page and a web search.”
This information comes directly from a January 2018 draft guidance FDA issued that provides practical information and recommendations about the use, content, and circumstances for industry to issue press about a recall. I found this guidance very helpful to share with the CEO, which I admit pleased me as I had helped develop the guidance the year before leaving the agency.
The good news? The food company and its law firm moved promptly. They worked closely with FDA’s recall coordinator who reviewed the press release and the plan for disseminating and posting the information that we had developed. I worked with a national news service to disseminate the press release, with the photos, and the company simultaneously posted the announcement prominently on its own website. The release was picked up in local markets across the country, and the public was alerted.
For years at FDA I had heard that most firms do what they are supposed to during recalls and that they go as planned. Now, from outside FDA, I saw evidence of that for myself. The CEO listened closely to his legal and communications advisors and made decisions quickly and responsibly. He coordinated closely with FDA and communicated promptly and transparently about the recall. That’s the way recalls are supposed to work, and it’s the best way to preserve and strengthen consumer confidence in a firm and its brands.
About the author: Sharon Natanblut now consults on policy and communications issues. Until February 2018, she served as senior advisor to the FDA Deputy Commissioner for Foods and Veterinary Medicine and Director of Strategic Communications and Stakeholder Engagement for the foods program. She previously served as deputy director of the FDA’s tobacco program and associate commissioner for strategic initiatives.
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