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"Our ability to retain information, obtain them
in a timely manner - they're all impacted by
information technology ... there's IT issues from
Health Canada's side. Certainly efficiency can be
improved if we have more information management systems that allow us to manage that information." (GOV-2)
One suggestion was that both the CFIA and Health
Canada could have a common management information
system to allow for more timely and integrated information
sharing and improved risk management.
Communication
In a recall, there is an urgency to recover the affected
product and notify the customer/consumer. Internal
communication may be neglected. Within a global company,
an escalation of communication is required, and the food
recall system must be designed from a global viewpoint.
In order for all senior quality managers within a global
company to be aware of, and knowledgeable about, issues
in one region, cross-regional communication must exist.
It is suggested that global companies create a forum
whereby all senior quality managers of each region decide
on communication responsibilities, i.e., the nature of the
information to forward and who communicates to whom,
and add that to their regional responsibility checklist.
Communication forums were discussed in a different
context as well. One recommendation by IND-2 was that a
forum be created to facilitate greater transparency through
the sharing of information and resources across companies.
This could include, but would not be limited to, sharing best
practices, what did and did not work from past recalls, and
providing suppliers with the tools to enable them to build
stronger recall programs. One participant explicitly shared
that there is currently apprehension about speaking out
regarding what went wrong in a recall, out of fear of punitive
action by the CFIA. However, a company sharing its recall
mistakes allows for other companies to learn from them,
rather than waiting for others to make similar mistakes.
The majority of industry interviewees (5 of 6) discussed
the importance of a company having a personal contact
within OFSR, as well as with their local inspector and
regional office. Importantly, the relationship with CFIA
should be treated as a partnership rather than viewing it
as adversarial. As one participant (IND-2) attested, asking
for CFIA's opinion on what can be done to prevent a given
issue - even if those recommendations that are sought are
based on best practices and not regulations - can create
an even stronger shared accountability. Communicating
with CFIA that there is a desire to be better, and that the
company believes CFIA has a responsibility to provide
them with that input, may provide industry with more
learning opportunities.
As part of CFIA's modernization initiatives, there have
been recent changes to the communication flow, whereby
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an individual company deals with the CFIA regional office
rather than directly with OFSR in Ottawa. The participant
who mentioned this (IND-3) perceived direct contact with
the Ottawa office to be more effective and timely. This is
because being asked questions by someone at the regional
office who may not have the most relevant background, and
who is always going to go to Ottawa to make a final decision,
leads to a great deal of unnecessary communication.
Food safety culture
Food manufacturers that are successful at empowering
employees and foster an environment where speaking out
about issues is encouraged are much more likely to embody
a culture of food safety. When employees are comfortable
outwardly sharing the problems that they have recognized
rather than turning a blind eye, and are given the power to
stop the production line if needed, issues are resolved in
production rather than during distribution or sale. Team
members can be trained and coached, but if they do not feel
safe, they will not verbalize issues or look for continuous
improvement opportunities. As one participant stated,
"We in most companies, I think, developed
in this industry long before we actually had
recall needs. Right, so, the recall processes are
add-ons, or bolt-ons, that are external to our
core business. And realistically, we really need
to come back and make it an absolute part of
the core that that information, that traceability,
that responsiveness, is a core part. And I know
it sounds airy, and fluffy, and too philosophical,
but it really comes down to everyone in the
chain knowing this is the most important thing
they can do at this moment." (IND-4)
A true culture of food safety will act as a driver of
effectiveness in recall prevention. There are, obviously,
challenges with this. Everyone within the organization
must have defined roles and responsibilities, especially
in dynamic organizations where positions are frequently
changing, and there must be a leader.
"You need to have a definitive leader that is
seen as a recall coordinator within the organization that can deal with all aspects of a recall."
(IND-1)
To help employees understand their responsibilities, an
organization could invest resources into holding a Kaizen
event for recall process mapping and for responsibility
checklist development. A Kaizen event, or Kaizen blitz, is
an intense and short-term improvement project held by a
team or department (17). Creating the proper documentation will clearly show each person/function/role what
information he/she needs to collect, what questions to ask,
and what information he/she needs to forward to others at
the time of a recall.

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