Between 2016 and 2017, the Food Standards Agency (FSA) and Food Standards Scotland (FSS) reviewed the UK food sector with the aim to improve the way food is recalled within the UK.
This review resulted in changes to the withdrawals and recalls system, including new guidance, changes to point of sales notices displayed in shops and additional training for food business operators (FBOs).
RSM’s review of the new recall system focused on two key objectives – to understand how the changes were carried out and to evaluate the success of the system redesign, the roles of the agencies, how aware the public is of the safety around their food and how the FSA/FSS can improve their work in the future.
Roles and responsibilities
On investigating the roles and responsibility in the new system, the review found that FBOs ESRG members and enforcement officers had a clear understanding of the new roles and responsibilities – an improvement on the old system, which was less direct about these.
However, while consumers who had experienced a recall said they had a clear understanding on their role, those who had not were less confident of their role during a food recall.
Accessibility of information
When consulted on the accessibility of information and cross industry sharing of approaches and impact, consumers were less likely to think that the information available isn’t as accessible than it is to enforcement officers and ESRG members.
Consumer focus groups thought that awareness of recalls was dependent on chance – for example, they happened to see a notice in store or read about a recall in a newspaper. This suggested that information is not always consistently available.
Finally, consumers thought that the duty was on retailers – as opposed to regulators – to inform consumers of a recall and that a range of communication methods should be used to inform them. Examples used included emails, loyalty schemes and posters in stores.
Public awareness of recalls
FBOs, ESRG members and consumers all had different views on how aware the public are of what to do during a food recall. FBOs said consumers often contacted them directly to ask about next steps during a recall, suggesting consumers weren’t always aware of what to do next.
Similarly to the investigation into roles and responsibilities, the review found that consumers who had experienced a recall were aware of the process, but those that had not were less aware of what they should do.
Improvements for the future
Reflecting on the above response, the review offered a number of improvements that could be made to the system in the future.
“There is limited evidence that all parts of the system are working together to share good practice and improve the system,” read the review. “For example, enforcement officers reported that not all businesses have been completing a Root Cause Analysis (RCA) after their recall, which helps to identify how the issue happened, and what they can do in the future.
“When FBOs do complete an RCA, they do not always share the findings more widely (I.e. with FSA/FSS on request in order to share with others in their industry). This is often due to limited awareness of how to share these findings. As a result, there are fewer opportunities to share learning across the food industry, local authorities and regulators.”
A full list of its recommendations can be found in the box below.
Considerations for improvement
For any future FSA/FSS project which requires team working, the FSA/FSS should adopt a similar approach (for example, making sure that the purpose of the workstreams is clear, and engaging regularly with all key stakeholders).
Because businesses were often not aware that guidance was available, the FSA/FSS should continue to raise awareness that the recalls guidance is available on their respective websites. When FBOs did access the guidance, they felt that it was helpful. Raising awareness could be done via trade organisations, LinkedIn posts or during local authority inspections.
Points of sale notices
Because there is often inconsistency in the style of point of sale notices, consider making the point of sale template compulsory for FBOs. As more consumers shop online, consider producing guidance on where these notices should be displayed online. The point of sales notice template could also include a QR code, as consumer focus groups thought that this would be helpful.
Continue to make consumers aware of the steps to take during a food recall (for example, at FSA/FSS stands at food shows or online advertisement campaigns), as data shows that awareness is still lower than expected. The current FSA/FSS text alert service (informing consumers about products that have been recalled), could be promoted more widely, as focus groups liked this idea.
Consider offering more tailored support for smaller FBOs, so they are clear on their role within the recall process. Smaller FBOs were less
likely than larger FBOs to have internal processes or resources in place in the event of a recall. Consider promoting the Quick Reference Guide with this group.
Communicating with consumers
Going forward, FBOs should use a mixture of ways to notify consumers of a recall (including existing methods such as point of sale notices in stores and newspaper advertisements, and online methods such as emails or loyalty app notifications).
Greater sharing of root cause analysis (RCA) findings
Make it clear who is responsible (either the FSA/FSS, local authorities or FBOs) for sharing RCA findings, and also how these findings could be shared. This would allow for continual improvement within the system. It may also be useful to create specific guidance for small/micro FBOs regarding RCAs.
The FSA/FSS could also create a national database of RCAs, accessible by all local authorities. This would be useful in monitoring any current recall trends, as well as exploring any emerging trends.
Further promotion of the RCA e-learning course
To increase the number of people completing the RCA e-learning course, consider asking local authorities to share the RCA e-learning course with FBOs as part of the recalls process. As suggested by enforcement officers, it might also be helpful to produce simplified RCA guidance for smaller FBOs.
Standardise data collection categories
Consider making the FSA and FSS data collection categories the same, which will help the organisations to monitor recall trends.