Week 36 Managing Incidents We’ve got SALSA sussed..!

We’ve got SALSA sussed..!

Week 36 Managing Incidents

Managing Incidents is an extremely important topic. It is a part of the SALSA Standard where a lot of Non-Conformances found in audits, due to businesses NOT carrying out their Mock Recall.

 

Incidents can come in many forms. The most serious can result in a Recall. This can be a very costly situation for various reasons. Business reputation, financial costs, human resource costs for example. We are going to look at setting up the Managing Incidents Procedure and testing that it works through a Mock Recall.

 

As I mentioned in the previous weeks, it is not a Traceability Test, although traceability is an element of a Mock Recall.

 

A Mock Recall is ‘testing that your team knows what to do’ if and when a Recall situation was to actually happen. You need each team member present at the Mock Recall, to carry out their role, follow the procedure, and make sure it works and it is understood.

 

There are other Incidents which might happen which are not as serious. However, could result in a ‘Near Miss’, such as a glass breakage which could contaminate food being prepared, an allergen spillage, a contaminated ingredient, metal contamination from damaged equipment, all of which can all be found and stopped before leaving the building. These types of incidents also need recording, so you can ‘Correct & Prevent’ from happening again.

 

Let’s check out how to tackle this one!

What’s coming next…Week 37 Complaints

Managing Incidents - what do you need to show your SALSA auditor?

Managing Incidents, Withdrawals & Recalls Procedure

Mock Recall

Incident Record

 

Being able to manage incidents effectively comes with experience. Having potentially serious incidents happen is not something you want as a business owner. This is why we have standards such as SALSA in place. If you have read through all of my Blogs and the SALSA Standard and you have implemented each of the requirements, the likelihood of a serious incident happening will be massively reduced.

 

However, Incidents can happen, unexpectedly, by accident (we are all only human), and for reasons beyond your control. Therefore, we must have a plan in place in case incidents arise. So, let us talk about what to put in your procedure…

 

Managing Incidents, Withdrawals & Recalls Procedure

Firstly, think about the types of Incident which could occur. We can break this down into 3 categories:

1.       Recalls

2.       Withdrawals

3.       On Site Incidents

 

The difference between a Recall and a Withdrawal is:

 

A ‘Recall’ means the product has been put out for Consumer Sale and consumers may have purchased and eaten the affected product.

 

A Food Standard Agency (FSA) Alert is necessary when a Public Recall is required.

 

The FSA publishes an Alert which is emailed to everyone who has signed up to the alerts. It is used by many allergy sufferers so that they are made aware.

 

I have signed up for all of the FSA Alerts to be emailed to me so that I can see what is going on in the food industry. It is very interesting, and Recalls happen more than you’d think, to small medium and large businesses. You can do this by signing up to Subscribe to News and Alerts on the FSA website…

 

You can find all of the Alerts here:

https://www.food.gov.uk/news-alerts/search/alerts

 

Retailers usually alert consumers ‘in store’ to any recalled product. The larger retailers who have the consumers details (such as through loyalty cards Nectar at Sainsburys for example) will contact the consumers directly if they know they have purchased the product.

 

Other ways to alert the consumers could be placing an article in the newspaper.

 

 

A ‘Withdrawal’ is where the product may have left your business but has NOT been put out for consumer sale. I.e., it is still in storage. Therefore, the full amount of product can be accounted for, retrieved and sent back to you or put to waste.

 

Other ‘On Site Incidents’ are where there is potential that an ingredient or product you are making or have made has been contaminated. Examples of these are; a glass breakage which could contaminate food being prepared, an allergen spillage, a contaminated ingredient, metal contamination from damaged equipment, all of which can all be found and stopped before leaving the building.

 

Recalls & Withdrawals

A Procedure for your team to follow to ensure they know what to do is necessary in order to carry out a Recall or Withdrawal successfully and efficiently.

 

A recall situation could come to light through receiving complaints (such as a contamination or illness complaint). Or it could be that you realise an incorrect Allergen Label has been applied to a product. If, or when this happens, all staff need to know to act upon it immediately. It needs to be prevented from reaching to other consumers as quickly as possible.

 

Document Your Team & Responsibilities

When it happens, who does what?

 

Document an ‘Incident Team’ within your procedure, with specific names and what their responsibilities are. You will need to train this procedure to your team and follow this procedure when you carry out your Mock Recall, so the clearer it is to follow the better.

 

I understand your teams might be small, however the Incident Team members might wear many hats. Still take into consideration all responsibilities and list who does what. The team needs to consist of the following roles and responsibilities:

 

Team Leader Role

A specific person should be in charge of co-ordinating the Recall or Withdrawal. They should co-ordinate the rest of the team to carry out their roles and document the incident on the Incident Record. On the Incident Record, they should document the dates and times at which everything happens, the products affected, batch numbers and quantities. This information should be given to them by other team members. The investigation into why it has happened should be documented on here too, however this comes afterwards.

 

Traceability Role

A staff member needs to be responsible for carrying out the traceability of the product. Finding out where the batch has been delivered to, i.e. which customers. They must ensure the full amount of the batch of product is found, what is still in storage on site and what has been sent to customer must total the full amount made. In some cases, there may be additional quantities which may have been put on the wastage, or samples sent to customers, or retained etc. It all needs accounting for.

 

Customer Communication Role

A person needs to be responsible for communications, to and from the customer.  All customers who have received the affected batch need to quantify how much they have, and if it has been put out for consumer sale, OR if it is still in storage. Once you have all of this information from all customers, you can make the decision on whether it is a ‘Recall’ or a ‘Withdrawal’.

 

Press Communications Role

If you have a serious issue where, for example, someone has had a serious reaction to an allergen which has not been listed on the label of your product, and it gets to the press, you need to make sure you have someone who is confident in speaking with the press. This person is usually the Business Owner or Director.

 

EHO/FSA/SALSA Communications Role

You need to have a team member who is responsible for communicating with the local authority (EHO) and the Food Standards Agency (FSA) as soon as a Recall is instigated. A Recall needs an FSA Alert instigating, and you will need to contact the FSA to carry this out. The FSA can complete the alert on your behalf, or you can log onto the FSA Alert System and put all of the details in yourself, then they will contact you to discuss.

 

https://reportanincident.food.gov.uk/

 

SALSA also need to be informed of the Recall situation if it were to happen. Not only Recalls, but also Withdrawals and Improvement Notices (which is what an EHO could possibly give to you). They require a summary of the investigation details into why it happened. Add this into your procedure too.

 

Having a documented list of all contact details within your Managing Incidents Procedure is a great idea, so that you only have one place to look for all of the information you need. The only list you might not be able to include if it is too big and not practical is your customers. Add the location of the document or system where you can find all of the customer information instead.

Incident Team
Role	Name	Contact Details
Team leader	Add	Add phone number(s)
Traceability
Customer Communications
Press Communications
EHO/FSA/SALSA Communications
Customers
Add	Add phone number(s)
Suppliers
Add	Add phone number(s)
Other Key Contacts
Local Authority EHO	Add names and phone number(s)
Food Standards Agency	Add names and phone number(s)
SALSA	Add names and phone number(s)

 

The procedure to follow is described within each role. However, it is a good idea to have a step-by-step guide. For example:

1.       Obtain the product batch number and quantity. Ensure you document it on your Incident Record (add the name and location of the document for ease of reference).

2.       Complete the traceability of the product. Use your Traceability Procedure. Quantify the amount that the Customers received, what remains in stock, any waste, samples retained, samples sent to customers etc.

3.       Contact customers to ascertain if the batch of product is in storage or put out for consumer sale.

4.       Decide if the issue is a Recall or a Withdrawal.

5.       Arrange the return of the affected product from your Customers, or ensure customers are informed that it must be put to waste. Ensure you have evidence of your customer contact (if calling by phone, back up with an email).

6.       Document all the Recall or Withdrawal information on your Incident Report, times, and dates.

7.       Contact your EHO & the FSA.

8.       Arrange the Alert with the FSA.

9.       Arrange for the Retail Customers to put the alert on their website or in store.

10.   If necessary, create your article for the newspaper.

11.   Complete and document your investigation into why this happened within 3 days, detailing your Corrective & Preventive Actions.

12.   Contact SALSA and send your investigation summary report to them.

 

Incident Record

Below are examples of an Incident Record where you must document everything about the Incident, Recall or Withdrawal, and a Mock Recall Record, where you can add your Mock Scenario (metal found in product/allergen not listed) and all of the team involved.

 

You must remember to gather all of the supporting documents you use for the Recall, such as Production Record for the batch, customer delivery notes confirming batch and quantity received, all email communications, Alert details, EHO communications etc. Keep all documentation in a ‘Mock Recall Documentation Pack’ to show your auditor.

 

Once you have completed your Mock Recall, if there was anything that didn’t go to plan, or the procedure is not quite right, something did not work, someone did not follow procedure, now is the time to put it right. That needs documenting in your Recall Results section of the Test Recall Record.

 

If the procedure was not quite right, correct it and retrain it.

 

If a person did not follow procedure, carry out a Refresher Training Session for them.

 

If the Traceability didn’t work as you couldn’t quantify all stock – put procedures in place so that you can (see the Traceability Test Blog from last week).

 

Correct & Prevent it from not working. Then plan another Mock!

 

Now hopefully you should be well equipped to deal with this one.

 

Please get in touch if you want to ask anything, I am here to help. Be careful and stay safe!

Ruth

Ruthshawconsultingltd@gmail.com 

07732 966 836

www.ruthshawfoodsafety.co.uk