October 15, 2021, Accra. “PRODUCT RECALL: CERES 100% APPLE JUICE”, FDA. You might haveseen a statement from the FDA with the above caption making the rounds on social mediabarely a week ago. This is the right opportunity to throw some light on product recalls and the
impact on your business. I will focus on the food & beverage industry since we are dealing with a typical beverage. The lessons though cut across all consumer goods. A product recall is the process of retrieving defective and/or potentially unsafe goods from consumers while providing those consumers with compensation. Recalls often occur as a result of safety concerns over a manufacturing defect in a product that may harm its user.

Why the Ceres 100% Appl Juice recall?

The Food and Drugs Authority released the above statement regarding the recall of certain batches of Ceres 100% apple juice on the Ghanaian market. According to Mr. Seth Seaneke who signed the statement on behalf of the Chief Executive Officer of the FDA, the affected variants/skus were specific batches of Ceres Apple 4x6x200ml Tetrapak, Ceres Apple Sparkling, 275ml Glass and Ceres Apple 12x1L. At the time of the release of this statement the recall process was ongoing. What triggered this recall? Mycotoxin-patulin levels had exceeded the regulatory threshold. Mycotoxins are toxic compounds that are naturally produced by certain types of moulds. Moulds that can produce mycotoxins grow on numerous foodstuffs such as cereals, dried fruits, nuts and spices. There are three types of mycotoxins which are of economic importance: Aflatoxins, Ochratoxins and Patulin. Aflatoxins are produced by certain moulds (Aspergillus flavus and Aspergillus parasiticus). Ochratoxins are produced by several species of Aspergillus and Penicillium and is a common food-contaminating mycotoxin. Patulin is a mycotoxin produced by a variety of moulds particularly Aspergillus, Penicillium and Byssochlamys.

Often found in rotting apples and apple products, patulin can also occur in various mouldy fruits, grains and other foods. The WHO takes the threats of mycotoxins so seriously that there is a joint FAO/WHO Expert Committee on Food Additives (JECFA) who does risk assessments of
mycotoxins in food and establishes maximum levels in food or provide other risk management advice to control or prevent contamination. The following lessons can be learnt from this incident:

Lesson 1: Have a robust incident management procedure and team

Food companies must have a product recall procedure which is based on risk assessments. Recalls may be categorized into two, public and silent recalls. A public recall happens when the issue triggering the recall has consumer safety implications. In a public recall, the products would have left the control of the company and already in retail outlets and possibly in consumer homes. A silent recall may happen when the issue triggering the recall is a quality issue and might not have any adverse health implications. Products might have left the control of the business in this case too. In the first instance, the regulatory body responsible is alerted and a public announcement through press statements, radio announcements and other public announcements are made to get the message to consumers in every cottage, hamlet, village, town and city. Silent recalls usually use a ‘submarine’ approach to retrieve products without such nationwide call to action. A well-established incident management team who has the resources to react faster to product defect issues in the trade is an asset. The Ceres Apply Juice incident should be a wake-up call to businesses in the food and beverage industry, especially to review their incident management procedures and establish an incident management team (IMT) which is up to the task to respond effectively and timeously.

Lesson 2: Build strong synergies with Regulatory Authorities

Internal analysis and following up on adverse results are key attributes of a company that is positioned to remain relevant to consumers. We are told from the FDA statement that the manufacturer of Ceres products, Pioneer Foods Groceries (Pty) Limited, South Africa together
with INFOSAN (International Food Safety Authorities Network) communicated this incident to the Food and Drugs Authority. The lesson here is the importance of collaboration between food companies and regulatory authorities to ensure consumers are protected from unsafe
products. The International Food Safety Authorities Network (INFOSAN) is a global network of 186 national food safety authorities, managed jointly by FAO and WHO with the secretariat in WHO. INFOSAN assists Member States in managing food safety risks, ensuring rapid sharing of information during food safety emergencies to stop the spread of contaminated food from one country to another. INFOSAN also facilitates the sharing of experiences and tested solutions in and between countries in order to optimize future interventions to protect the health of consumers.

Lesson 3: Prevention is better than cure

Public recalls like this can have a backlash on all other products manufactured by the company. Psychologically, consumers may think other batches and even other variants may also contain the contaminant in question and may stop buying for a while (the-wait-and-see-attitude). This may impact hugely on sales. Worse still, others may take the public recall to mean every single batch on the market is affected and make so much noise that, consumers may ignore the contents of the original message and feed on the misconception. In this particular case a message on one of the WhatsApp platforms stated “Public Warning…FDA is recalling all Ceres 100% Apple Juice. It’s got done high levels of toxins” (quoting unedited). It took another person on the same platform to post the original statement of the FDA and added “Not all please… It’s a particular batch. Kindly re-check the comms”.

Assuming the correction never came, most of the over 160 people on the platform may have believed this misleading information which could have led to a boycott of all Ceres 100% Apple Juices on the market to the disadvantage of Transmed Ghana Limited, the importer. In short,
avoid public recalls by tightening food safety measures in your food establishment.

Lesson 4: Establish strong food safety management and QA systems

Monitoring recalls is a lagging indicator and hence may not be your first KPI. Prevention of recalls through a functioning food safety management system is important. Food businesses must invest in the establishment of HACCP (Hazard Analysis and Critical Control Points) systems to ensure the effective identification, evaluation and control of hazards that are significant to food safety. Quality Assurance is providing the confidence that the food being offered meets requirements and hence a strong QA system is an asset to the business.

Conclusion

It is welcoming news that all the stakeholders in this case were proactive in getting the recall underway. As a consumer watch out for the batches indicated in the FDA statement release and hand any such product over to the nearest Transmed depot or the nearest FDA office. Product recalls occur as a result of safety or quality concerns related to a manufacturing or design defect in a product that may harm its users. It is therefore key that a preventative approach is employed in food processing. Invest in an effective food safety management system based on ISO 22000 and a strong Quality Assurance system. Finally, put together an effective incident management procedure, a professional incident management team and conduct a mock product recall at least once a year to test the effectiveness of your traceability system and incident management procedure.

Johnson Opoku-Boateng is the Chief Executive & Lead Consultant, QA CONSULT (Consultants and Trainers in Quality Assurance, Health & Safety, Environmental Management systems, Manufacturing Excellence and Food Safety). He is also a consumer safety advocate and helps businesses with regulatory affairs. He can be reached on +233209996002, email: johnson@qaconsultgh.com.