MANAGING FOOD RECALL MANAGEMENT IN NIGERIAN

FOOD AND BEVERAGE INDUSTRY

With Food contamination on the rise, growing by 78% in 2016, with the probability of extension far
beyond in 2016. Even, food multinationals such as MARS and NESTLE that maintain private
standardized strict quality management system mechanism, policy, objectives and perform extensive
due diligence on their production and suppliers are not exempted, sometimes facing prospect of
recall or product reliability claims. And with the Nigerian Food and beverage industry production and
supply chain been long and complex, even problems experienced by small, large food processors and
manufacturers can lead to, and recently have resulted in low sub- standard Food products which may
lead to widespread recalls if not quickly and carefully addressed causing millions of naira in product
recall cost and potential tort liability for numerous other food manufacturers, distributors and
retailers.

The Nigerian Food Industry especially the food and beverage industry is not immuned to this
devastating shock that has taken the World Food Industry by storm leading to +200% from 1999-
2015leading to a cost of $55.5 billion.

A food recall is one the most devastating things that can happen to any organization or multi-
nationals within the Food industry.

Recently in Nigeria, publicity has increased surrounding recalls of food products such as Taste Brown
beans, Peanut chips, and Sesame seeds etc. from its markets due to contaminations

There is a great need about Nigerians Food Companies establishing measures to effectively mitigate
recall risk, or if a recall is necessary, to manage the process as quickly and efficiently as possible.

Though brand equity is imperative to an organizations success. Added to the cost to consumers and
are regulatory issues, negative customer and consumers reactions to address, as well as the possible
effect on market share to consider.

In the unfortunate event of a recall, the Nigerian Food Companies and multinationals must react
immediately by following the best practices of recall management; it must have an established plan
so that there is no question about the course of action and who must be involved in each step.
Conducting mock recall the best possible way to ensure that all processes are still effective. In light
of this trend, food companies and multi-nationals at all levels of production, supply chain should
prepare a careful recall risk mitigation plan for recall management by following this four essential
steps:

1. Recall Plan: For a recall management a recall plan must be established at this point if the
organization does not already have one in place. A recall plan is an important part of an
efficient Recall Management system. Every organization should have a plan in place in the
event of a recall and should conduct drills or mock recalls on their plan to guarantee its
effectiveness. This helps to ensure that in the event of a recall, all of the necessary steps are
 executed thoroughly and correctly, the first time. The recall plan covers everything from the
submission of information to the Regulatory body (NAFDAC) and how the public will be
notified to the evaluation of the recall. It is essentially the companys mapped out areas of the
recall process, telling them exactly which direction they need to go for each step in the
process.

2. Submitting the Recall Information to Regulatory agency (NAFDAC): Once it is determined that
food product warrants a recall, the process must be swiftly put into action. NAFDAC must
receive all information related to the product such as the name of the recalling firm, name of
manufacturer, as well as the reason for the recall, including a description of exactly how the
product is defective, how the product is defective, how this has affected the safety of the
product, and the date the issue occurred. NAFDAC Health Hazard Evaluation (HHE) form,
which shows the organizations assessment of the health risk, must be completed and sent to
NAFDAC. The company must also include the volume of product that was produced. They will
need to submit the distribution pattern and inform NAFDAC of the number direct accounts
that they deal with in order to retrieve all products back from facilities and consumers.

3. Notify the Public: Once the recall information has been submitted to the NAFDAC and the
recall plan has been put into place, the organization must then notify all parties involved. This
can be through various media channels, including press releases or recall notification letters
to consumers and facilities. All recall notification letters must include the identification and
description of the problem, and the depth to which recall has been implemented, whether
retail, wholesale, or user level. This step must also include detailed return instructions for
customers as well as a return response form.

4. Evaluate the Recall: Once the public has been notified and the recall has been initiated, the
organization must then conduct a recall evaluation to check its effectiveness. This will enable
the organization to benchmark its effectiveness and assess the progress of the ongoing recall.
During this stage, recall status reports must be created. These status reports should consist
of the date each customer was notified, the number of customers who responded, the
quantity of product that was accounted for returned, as well as the details of the effectiveness
check.

On discovery of the root cause of recall, the information should be sent to the local NAFDAC Regional
Office along with corrective actions which have been established at this point. Termination of recall is
the final step and can be started once it is determined that all parties involved have been notified,
and all traces of the product would have been recovered. Before, the NAFDAC will consider
termination a final status report should also be sent to the local NAFDAC Regional Office.

Recall Management is a necessity which must be put in place by Policy makers in the Nigerian Food
and beverage industry businesses today; but the best and most effective means is through
Automated Quality Management System (QMS) which seamless compliance with best practices of
Recall Management.
There is need in strengthening and modernizing existing food safety laws and standards available for
use in Nigerian Food Industry. Throughout the world heavy regulations and provision of technical
standard for the food industry is essential as it pertains to health and well-being of the people.
Hence, it mustnt be taken with levity as adulterations; contamination will have negative effect on
health affecting performances and the economy at large.

The Nigerian government needs to strengthen Institutional capacity of food safety as implemented in
its food safety policy which was launched in 2014 by the Federal Ministry of Health which can be a
Regulatory framework of developing its laws and policies which will encompass new globalized and
modernized suggested food safety Acts which are already available. Such Acts needed in Nigeria to
enhance our food safety laws are:

1. Food Globalization Acts: This Act would enable the NAFDAC to order recalls, require that all
products be traceable through the use of electronic records, fine non-compliant organizations, and
protect whistle blowers from retaliation.
2. Food Safety Enhancement Acts: This Act would serve as proactive measure for food safety
by preventing food safety problems. It would create an up-to-date registry of all food facilities that
serve consumers in Nigeria and requires all Nigerian food manufacturers and food importers to
register annually with government membership departments e.g. NAFDAC
3. Food Safety Enforcement Acts: This acts would requires food companies to implement food
safety plans, and register with Federal Ministry of Health under Public Health Services annually. It
would allow the NAFDAC to or do recalls detain unsafe food and set traceability requirements.
4. Food Safety Modernization Acts: This initiative would strengthens enforcement by granting
the NAFDAC capabilities that include ordering recalls, requiring that all products be traceable,
detaining and destroying unsafe food, and applying civil fines to those organizations that break
laws.

Before the food industry can develop practical approaches to reducing the number of food recalls, it
is important to understand the nature of the problems that lead to these recalls. A closer look shows
that there are patterns and trends and suggestions that the number of food recalls can be
significantly reduced through improved awareness and simple changes in the way that productions,
packages, labels and ingredients are handled and tracked within production facilities.