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CRISIS MANAGEMENT2107

Steven C SeidemanSteven C Seideman

Extension Food Processing SpecialistExtension Food Processing Specialist

Cooperative Extension ServiceCooperative Extension Service

University of ArkansasUniversity of Arkansas

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PURPOSE

This series is designed to help food processing This series is designed to help food processing companies develop and implement a companies develop and implement a CrisisCrisis Management PlanManagement Plan that addresses all possible crises that addresses all possible crises that can arise.that can arise.

The suggestions contained herein are very The suggestions contained herein are very general. Each food processing company should general. Each food processing company should design a crisis management plan that addresses its design a crisis management plan that addresses its particular products and overall organization.particular products and overall organization.

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INTRODUCTION

A “Crisis” can be defined as those A “Crisis” can be defined as those unexpected events, whether of human or a unexpected events, whether of human or a natural catastrophe, that can cause a food natural catastrophe, that can cause a food plant to close or otherwise interfere with the plant to close or otherwise interfere with the normal course of business, or that can cause normal course of business, or that can cause the public to lose its trust in an entire the public to lose its trust in an entire company.company.

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INTRODUCTION

Crises has become a reality in today’s food Crises has become a reality in today’s food processing companies ranging from processing companies ranging from microbiological food poisoning to product microbiological food poisoning to product tampering. These crisis situations lead to tampering. These crisis situations lead to loses of markets, legal lawsuits and can loses of markets, legal lawsuits and can virtually ruin a food company.virtually ruin a food company.

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Even through food related crises cannot be prevented, they can be MANAGED

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EXAMPLES OF RECENT FOOD RELATED CRISIS

EVENTS Poison in Tylenol bottlesPoison in Tylenol bottles Glass in baby foodsGlass in baby foods Recalls of ground beef with E Coli 0157:H7Recalls of ground beef with E Coli 0157:H7 Sara Lee processed meats with Listeria Sara Lee processed meats with Listeria

Monocytogenes.Monocytogenes. McDonald’s “Hot Coffee” and “Obese Adolescent McDonald’s “Hot Coffee” and “Obese Adolescent

Children”.Children”. Jack In The Box- E.Coli 0157;H7.Jack In The Box- E.Coli 0157;H7.

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CRISIS EVENTS

Although none of these crises were Although none of these crises were intentional and usually not even known to intentional and usually not even known to the parent food company when it happened, the parent food company when it happened, they still can have deleterious effects on the they still can have deleterious effects on the future of the business.future of the business.

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CRISIS EVENTS

By anticipating and detailed planning for a By anticipating and detailed planning for a crisis before it happens can drastically crisis before it happens can drastically minimize it’s ultimate effects on the minimize it’s ultimate effects on the company.company.

““Failing to plan is like planning to fail”Failing to plan is like planning to fail” ““The best defense is a strong offense” The best defense is a strong offense”

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Situation

You are the President of XYZ Food You are the President of XYZ Food Company and you are walking to your car Company and you are walking to your car at the end of the day. A news reporter at the end of the day. A news reporter comes up to you and says “Several people comes up to you and says “Several people in Wayne AR have just become seriously ill in Wayne AR have just become seriously ill and have implicated your food product. and have implicated your food product. Would you care to comment?” How would Would you care to comment?” How would you respond?you respond?

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OPTIONS

How would you respond?;How would you respond?; A) Tell the reporter “Sounds like a personal problem A) Tell the reporter “Sounds like a personal problem

to me”.to me”. B)Tell him you don’t have time to talk to him now B)Tell him you don’t have time to talk to him now

because you are tired.because you are tired. C)Tell him “No comment” C)Tell him “No comment” D)Tell him you are sorry about the whole incident and D)Tell him you are sorry about the whole incident and

you will launch a full investigation.you will launch a full investigation. E)Tell him that you think the liberal media probably E)Tell him that you think the liberal media probably

staged the whole thing to get a good story.staged the whole thing to get a good story.

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CORRECT ANSWER

Answer D is by far the best answer if you Answer D is by far the best answer if you have thought it through. Answer C is not have thought it through. Answer C is not too bad either. After any major problem, all too bad either. After any major problem, all the public expects to hear is concern for the the public expects to hear is concern for the victims and that the company is doing victims and that the company is doing something (investigating, making something (investigating, making restitution, cleaning up the mess etc). restitution, cleaning up the mess etc).

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THE POINT

The point of this story is that by preparing for a The point of this story is that by preparing for a wide range of crises, a company will know how to wide range of crises, a company will know how to respond to it. The President of XYZ Foods may respond to it. The President of XYZ Foods may not have been aware of the crisis but he had been not have been aware of the crisis but he had been trained to know what people expect.trained to know what people expect.

It has been repeatedly shown that all the general It has been repeatedly shown that all the general public expects for the first few days after a crisis is public expects for the first few days after a crisis is concern for the victims and to state that some concern for the victims and to state that some action will be taken.action will be taken.

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Crisis Management

This series will help you get started into This series will help you get started into crisis management training and through a crisis management training and through a crisis management unit, anticipate and plan crisis management unit, anticipate and plan details on how to respond to any possible details on how to respond to any possible situation that arises.situation that arises.

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Crisis Planning

Although every crisis will be disruptive and Although every crisis will be disruptive and unpredictable in various aspects and degrees, it is unpredictable in various aspects and degrees, it is possible to anticipate many of the decisions that possible to anticipate many of the decisions that will have to be made during a corporate crisis. By will have to be made during a corporate crisis. By outlining in advance the precise steps that outlining in advance the precise steps that corporate management and other personnel are to corporate management and other personnel are to address in identified crisis situations (who is to do address in identified crisis situations (who is to do what and how they are to do it) the ability of a what and how they are to do it) the ability of a company to respond efficiently and effectively is company to respond efficiently and effectively is greatly enhanced.greatly enhanced.

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Crisis Planning

Data suggests that the more potential crises Data suggests that the more potential crises an organization can think of beforehand and an organization can think of beforehand and prepare for (whether it can completely prepare for (whether it can completely prevent them or not), the more quickly and prevent them or not), the more quickly and successfully it will recover from any crisis successfully it will recover from any crisis that happens.that happens.

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Crisis Planning

Many potential crises can be prepared for in Many potential crises can be prepared for in advance since many crises send out a advance since many crises send out a repeated and persistent trail of early repeated and persistent trail of early warning signals. If one can identify the warning signals. If one can identify the potential problems and plan for them, the potential problems and plan for them, the probability of a successful recovery will be probability of a successful recovery will be greater.greater.

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THE STEPS IN CRISIS MANAGEMENT

Step #1Step #1; Form a Crisis Management Unit.; Form a Crisis Management Unit. Step#2Step#2; Make a list of all possible crises ; Make a list of all possible crises

one can think of.one can think of. Step #3Step #3: Write out an action plan for each : Write out an action plan for each

of the possible crises listed in #2.of the possible crises listed in #2. Step #4Step #4; Publish and distribute a Crisis ; Publish and distribute a Crisis

Management booklet to all responsible Management booklet to all responsible parties. parties.

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Let’s discuss each of these steps in greater detail

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Step #1; Form a Crisis Management Unit

Referred to as the CMU (Crisis Referred to as the CMU (Crisis Management Unit).Management Unit).

This unit is composed of key management This unit is composed of key management personnel who direct a crisis. personnel who direct a crisis.

The CMU is a group of managers that serve The CMU is a group of managers that serve to direct a crisis into a more favorable to direct a crisis into a more favorable situation or minimize its deleterious effects. situation or minimize its deleterious effects.

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Forming a Crisis Management Unit

The group is made up of members from various The group is made up of members from various departments who can rapidly respond to a departments who can rapidly respond to a situation, communicate with individuals, internal situation, communicate with individuals, internal and external to the company, be responsible for and external to the company, be responsible for determining the details of a crisis, identifying determining the details of a crisis, identifying needs and ultimately controlling the situation.needs and ultimately controlling the situation.

The president or plant manager will ultimately The president or plant manager will ultimately have to appoint a CMU committee since every have to appoint a CMU committee since every plant and peoples personality vary greatly.plant and peoples personality vary greatly.

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The CMU Team

TitleTitle

Plant Manager or VP Plant Manager or VP OperationsOperations

HR ManagerHR Manager

QA ManagerQA Manager

R&D PersonR&D Person

Maintenance ManagerMaintenance Manager

Shipping SupervisorShipping Supervisor

ResponsibilityResponsibility

Director of the CMUDirector of the CMU

SpokespersonSpokesperson

Assist in recallsAssist in recalls

Assist in technical issuesAssist in technical issues

Assist with engineering Assist with engineering problemsproblems

Assist with recallsAssist with recalls

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The CMU Team

Since every company varies in its products Since every company varies in its products and personalities, teams must be and personalities, teams must be constructed of the right people and assigned constructed of the right people and assigned responsibilities commensurate with their responsibilities commensurate with their talents.talents.

Additional members may be sales, the Additional members may be sales, the safety director, marketing, HAZMAT team safety director, marketing, HAZMAT team leader, First Responders team leader etc.leader, First Responders team leader etc.

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Two teams all plants should have

Every food processing plant should have a Every food processing plant should have a HAZMAT team and a First Responders team.HAZMAT team and a First Responders team.

The HAZMAT team are usually maintenance The HAZMAT team are usually maintenance people who are trained to handle HAZARDOUS people who are trained to handle HAZARDOUS MATERIAL in the plant such as ammonia, MATERIAL in the plant such as ammonia, chemical spills, etc.chemical spills, etc.

First Responders are the plants “first aid “people First Responders are the plants “first aid “people who are volunteers and trained to respond to who are volunteers and trained to respond to emergency situations.emergency situations.

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Why Bioterrorism

Poor man’s nuclear arsenalPoor man’s nuclear arsenal Used against living organismsUsed against living organisms

PlantsPlants AnimalsAnimals

Discussions have been primarily centered Discussions have been primarily centered around humans around humans

Why not against livestockWhy not against livestock

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HAZMAT AND FIRST RESPONDERS

Although I have never been on either of Although I have never been on either of these teams, I have personally witnessed these teams, I have personally witnessed both groups save people’s lives.both groups save people’s lives.

If you have ever seen these teams in action If you have ever seen these teams in action that are well trained, disciplined and cool in that are well trained, disciplined and cool in a crisis, you will never forget their a crisis, you will never forget their importance.importance.

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CMU RESPONSIBILITIES

Each team must have a director and alternate Each team must have a director and alternate director.director.

Each team needs to have a spokes-person for Each team needs to have a spokes-person for communicating with TV, radio and the press. This communicating with TV, radio and the press. This person has to determine when and the amount of person has to determine when and the amount of media coverage and when and how to keep the media coverage and when and how to keep the employees informed of a crisis. No other person at employees informed of a crisis. No other person at the plant or any member of the CMU should ever the plant or any member of the CMU should ever discuss any matters with members of the media no discuss any matters with members of the media no matter what happens. This can be real important.matter what happens. This can be real important.

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CMU RESPONSIBILITIES

The Technical person and QA Manager may be The Technical person and QA Manager may be one in the same. They are on the team for one in the same. They are on the team for purposes of advising in technical matters, recalls, purposes of advising in technical matters, recalls, laboratory analysis and other food safety issues.laboratory analysis and other food safety issues.

Maintenance and shipping supervisors are on the Maintenance and shipping supervisors are on the team to handle matters concerning their respective team to handle matters concerning their respective departments area of expertise.departments area of expertise.

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CRISIS EVENTS

No matter what the crisis, there are a series No matter what the crisis, there are a series of characteristics/events that take place.of characteristics/events that take place.

The CMU must realize these characteristics The CMU must realize these characteristics exist and control the situation.exist and control the situation.

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CRISIS CHARACTERISTICS

Characteristic/EventCharacteristic/Event1) Surprise1) Surprise

2)Insufficient information2)Insufficient information

3)Escalating flow of events 3)Escalating flow of events

CMU ResponseCMU Response

1)Collect the CMU and 1)Collect the CMU and assign tasks.assign tasks.

2)Collect factual data.2)Collect factual data.

Make necessary comment Make necessary comment to the media.to the media.

3)CMU should have control 3)CMU should have control by now. Facts about the by now. Facts about the crisis should be knowncrisis should be known

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CRISIS CHARACTERISTICS

4)Loss of Control4)Loss of Control

5)Intense scrutiny from 5)Intense scrutiny from outside.outside.

6)Siege mentality6)Siege mentality

7)Panic7)Panic

8)Short term focus8)Short term focus

5)Work through the media 5)Work through the media to keep a good company to keep a good company image.image.

8)Keep CMU on the right 8)Keep CMU on the right track of fixing the track of fixing the original problemoriginal problem

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CRISIS CHARACTERISTICS

The previous 8 steps will happen no matter The previous 8 steps will happen no matter what the crisis and will proceed in that what the crisis and will proceed in that order unless the CMU can stop it at any of order unless the CMU can stop it at any of the 8 steps.the 8 steps.

All 8 of these steps usually happen in the All 8 of these steps usually happen in the first 3-5 days of a crisis.first 3-5 days of a crisis.

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Step #2; List Possible Types of Crises

Crises can be divided into 2 typesCrises can be divided into 2 types. .

*Those that are plant or local.*Those that are plant or local.

*Those that require Corporate input.*Those that require Corporate input.

If you are a small company, these are one in If you are a small company, these are one in the same.the same.

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Plant and Local Crises

These types of crises are local in nature and These types of crises are local in nature and involve an expanded CMU structure, are involve an expanded CMU structure, are local in media coverage and only require local in media coverage and only require corporate knowledge of the crisis.corporate knowledge of the crisis.

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Crisis Requiring Corporate Input

These crises are ones that effect the These crises are ones that effect the corporation because of potential media corporation because of potential media coverage. coverage.

They are also characterized as ones where They are also characterized as ones where the product has physically left the the product has physically left the production facility.production facility.

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TYPES OF CRISES

LocalLocal

Ammonia leaksAmmonia leaks

Bomb threatsBomb threats

FiresFires

ExplosionsExplosions

Power outagesPower outages

TornadosTornados

CorporateCorporate

Adulteration/TamperingAdulteration/Tampering

Food poisoningFood poisoning

BioterrorismBioterrorism

RecallsRecalls

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UPDATE

Up to this point: Up to this point: 1) You have identified a CMU team and clearly 1) You have identified a CMU team and clearly

identified the responsibilities of each of the identified the responsibilities of each of the members.members.

2)You have made a list of all possible crises that 2)You have made a list of all possible crises that can possible happen.can possible happen.

Now you are ready to go through each potential Now you are ready to go through each potential crisis and write down what the action steps will be crisis and write down what the action steps will be taken if it were to happen.taken if it were to happen.

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Step #3; Write out an action plan for each possible crisis

This may seem overly simple as you do it This may seem overly simple as you do it but it is real important to detail it while you but it is real important to detail it while you are calm and thinking. When a real crisis are calm and thinking. When a real crisis comes along, you will probably be comes along, you will probably be surprised, in shock and extremely distracted surprised, in shock and extremely distracted so your thinking will be powered by so your thinking will be powered by emotion rather than logic.emotion rather than logic.

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Step # 3; Action Planning

Have some fun with this one. Take one possible Have some fun with this one. Take one possible crisis at a time and think of every possible way to crisis at a time and think of every possible way to handle using brainstorming and creativity handle using brainstorming and creativity techniques.techniques.

Remember that it is always better to be Remember that it is always better to be “proactive” to a crisis where the CMU has thought “proactive” to a crisis where the CMU has thought it through rather than being “reactive” where you it through rather than being “reactive” where you are acting out of emotion.are acting out of emotion.

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In Planning for a Crisis

REMEMBERREMEMBER

DETAIL DETAIL DETAILDETAIL DETAIL DETAIL

““The success to which one achieves in direct The success to which one achieves in direct proportion to their dedication to excellence”proportion to their dedication to excellence”

You must be dedicated to the excellence of You must be dedicated to the excellence of planning for the Crisis.planning for the Crisis.

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Step #3; Action Planning

We will now go through each of the general crises We will now go through each of the general crises with some thoughts on them. The following are with some thoughts on them. The following are not action plans by a few comments about the not action plans by a few comments about the crisis that should be considered as the CMU writes crisis that should be considered as the CMU writes the action plan.the action plan.

It is up to the CMU to write out a detailed action It is up to the CMU to write out a detailed action plan on each of these that can be distributed plan on each of these that can be distributed throughout the company.throughout the company.

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Ammonia Leaks

When an ammonia leak is detected by sensors or When an ammonia leak is detected by sensors or smell, the HAZMAT team and First Responders smell, the HAZMAT team and First Responders should be summoned.should be summoned.

All other employees should be evacuated from the All other employees should be evacuated from the area.area.

After the HAZMAT team has collected After the HAZMAT team has collected information as to where the leak is and the how it information as to where the leak is and the how it happened, the CMU can be briefed on the happened, the CMU can be briefed on the situation and decide what steps to take.situation and decide what steps to take.

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Bomb Threats

All bomb threats should initially be treated as if All bomb threats should initially be treated as if they were real, although most turn out to be a they were real, although most turn out to be a hoax.hoax.

Most bomb threats are made via the telephone. Most bomb threats are made via the telephone. Therefore, switchboard operators must be trained Therefore, switchboard operators must be trained on how to respond.on how to respond.

It may be good to have some simulated bomb It may be good to have some simulated bomb threat calls with switch board operators so that threat calls with switch board operators so that when a real call comes in, their reaction will be when a real call comes in, their reaction will be one of careful thought versus panic.one of careful thought versus panic.

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BOMB THREATS

The person receiving a bomb threat should;The person receiving a bomb threat should;

1)Remain calm but advise the caller that many 1)Remain calm but advise the caller that many innocent people might be hurt.innocent people might be hurt.

2)Keep the caller on the line as long as possible and 2)Keep the caller on the line as long as possible and attempt to get such information as time remaining attempt to get such information as time remaining until detonation and location and type of device. If until detonation and location and type of device. If at all possible, the operator should try to get at all possible, the operator should try to get someone to call the police while the caller is on someone to call the police while the caller is on the line.the line.

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Bomb Threats

3)Take careful notes of EVERYTHING that the 3)Take careful notes of EVERYTHING that the caller tells you. Also try to collect any additional caller tells you. Also try to collect any additional information you can such as background sounds, information you can such as background sounds, Is the call from the outside or inside the plant?; Is Is the call from the outside or inside the plant?; Is it an operator assisted call?; Is the caller a male or it an operator assisted call?; Is the caller a male or female?; Any particular speech or words that female?; Any particular speech or words that sound unusual?sound unusual?

4)Ask “Who is calling?” several times. You might 4)Ask “Who is calling?” several times. You might catch the caller off-guard.catch the caller off-guard.

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Bomb Threats

As soon as the caller terminates the As soon as the caller terminates the conversation, the operator should conversation, the operator should IMMEDIATELY notify the plant manager IMMEDIATELY notify the plant manager or senior member of management on duty.or senior member of management on duty.

It is up to the plant manager to evaluate the It is up to the plant manager to evaluate the threat and determine the appropriate action threat and determine the appropriate action to be taken.to be taken.

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Explosions & Fires

Explosions and fires can be covered in a Crisis Explosions and fires can be covered in a Crisis Management booklet under the same heading Management booklet under the same heading because most of the time they happen together or because most of the time they happen together or one may cause the other to happen.one may cause the other to happen.

Anyone discovering a fire should immediately Anyone discovering a fire should immediately contact the central operator (or however you write contact the central operator (or however you write your plan) and then immediately evacuate the your plan) and then immediately evacuate the area. Pull any alarms in the area. While exiting, area. Pull any alarms in the area. While exiting, every employee should be notifying other co-every employee should be notifying other co-workers to evacuate the building .workers to evacuate the building .

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Explosions & Fires

Maintenance or whoever is designated in the Maintenance or whoever is designated in the CMU booklet should be in front of the plant to CMU booklet should be in front of the plant to direct the fire department to the area involved.direct the fire department to the area involved.

Your CMU booklet should have a map of the Your CMU booklet should have a map of the evacuation routes in the plant. These evacuation evacuation routes in the plant. These evacuation routes should be posted throughout the plant and routes should be posted throughout the plant and new employees should be made aware of them.new employees should be made aware of them.

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Explosions & Fires

During the initial stages of a fire, the plant During the initial stages of a fire, the plant manager will determine what areas, if any, manager will determine what areas, if any, need to be evacuated. If the decision is need to be evacuated. If the decision is made to evacuate the plant, the members of made to evacuate the plant, the members of the First Responders, HAZMAT team and the First Responders, HAZMAT team and maintenance may be used to aid in the maintenance may be used to aid in the evacuation. evacuation.

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Power Outages

The loss of electrical power is not a major The loss of electrical power is not a major problem for most plants unless it is for an problem for most plants unless it is for an extended period of time. extended period of time.

It could be assumed that this problem may It could be assumed that this problem may occur in conjunction with other emergency occur in conjunction with other emergency type situations. This would mean that those type situations. This would mean that those situations would then become more difficult situations would then become more difficult to handle.to handle.

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Power Outages

The loss of electrical power causes;The loss of electrical power causes; *A loss of regular lighting*A loss of regular lighting *A loss of regular phone service*A loss of regular phone service *A loss of refrigeration *A loss of refrigeration The CMU should anticipate what precautions should The CMU should anticipate what precautions should

be taken to;be taken to;1)How to evacuate people in remote areas of the 1)How to evacuate people in remote areas of the

plant.plant.2)Where to go for refrigeration.2)Where to go for refrigeration.

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Tornadoes

Most tornadoes occur in the midwest and south Most tornadoes occur in the midwest and south central states between March and September.central states between March and September.

Tornadoes are usually proceeded by Tornadoes are usually proceeded by thunderstorms and clouds that have a greenish-thunderstorms and clouds that have a greenish-black color. black color.

Plants should have a designated person to monitor Plants should have a designated person to monitor the radio when conditions are right for a tornado.the radio when conditions are right for a tornado.

There are two types of tornado alerts.There are two types of tornado alerts.

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Tornadoes

A “Tornado Watch” means that conditions A “Tornado Watch” means that conditions are right for a tornado but none have yet are right for a tornado but none have yet been spotted.been spotted.

A “Tornado Warning” means that someone A “Tornado Warning” means that someone has actually confirmed the presence of a has actually confirmed the presence of a tornado. This is where management must be tornado. This is where management must be readily available to decide if and when readily available to decide if and when emergency plans begin.emergency plans begin.

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Tornados

Prior planning by the CMU should decide where Prior planning by the CMU should decide where employees are to go when a tornado is heading for the employees are to go when a tornado is heading for the plant. A simple plant map similar to the one used for plant. A simple plant map similar to the one used for evacuation routes should be developed to show evacuation routes should be developed to show employees where to seek shelter.employees where to seek shelter.

Your local police or fire departments can help you Your local police or fire departments can help you determine the safest places to seek shelter in your determine the safest places to seek shelter in your facility (e.g. along north walls; away from windows etc).facility (e.g. along north walls; away from windows etc).

Do not allow employees to leave the facility if a tornado Do not allow employees to leave the facility if a tornado is approaching. Flying debris in a tornado can injure is approaching. Flying debris in a tornado can injure people.people.

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MAJOR CRISIS SITUATIONS

We have previously covered smaller, We have previously covered smaller, localized crisis situations.localized crisis situations.

We will now cover major crisis situations We will now cover major crisis situations that are more difficult to handle and can that are more difficult to handle and can have devastating effects on the future of the have devastating effects on the future of the organization.organization.

These include adulteration/tampering, food These include adulteration/tampering, food poisonings, bioterrorism and recalls.poisonings, bioterrorism and recalls.

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MAJOR CRISIS SITUATIONS

More difficult to handle because of geographic More difficult to handle because of geographic distances--the food has left the plant and detailed distances--the food has left the plant and detailed information is harder to obtain.information is harder to obtain.

More difficult to handle and more devastating More difficult to handle and more devastating because the media coverage has now become because the media coverage has now become regional or even national.regional or even national.

More difficult to handle because if you are part of More difficult to handle because if you are part of a larger corporation, additional people are now a larger corporation, additional people are now involved.involved.

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Major Crisis Situations

Because of the expanded media coverage, Because of the expanded media coverage, the members of the CMU are the only plant the members of the CMU are the only plant personnel that need to be involved.personnel that need to be involved.

The 8 steps of Crisis Events still happen as The 8 steps of Crisis Events still happen as previously mentioned.previously mentioned.

If you have ever been through a recall or If you have ever been through a recall or any or the major crisis situations, you know any or the major crisis situations, you know the need for forward planning in detail. the need for forward planning in detail.

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Action Plan for Major Crisis Situations

1)The CMU is assembled and discusses what is 1)The CMU is assembled and discusses what is known. An action plan is developed based on what known. An action plan is developed based on what is known and tasks assigned to CMU members is known and tasks assigned to CMU members based on crisis templates in the CMU booklet.based on crisis templates in the CMU booklet.

2)If part of a larger corporation, the corporate office 2)If part of a larger corporation, the corporate office needs to be notified along with any relevant needs to be notified along with any relevant government agencies such as FSIS, FDA, FBI etc.government agencies such as FSIS, FDA, FBI etc.

3)Expand the CMU if necessary. 3)Expand the CMU if necessary.

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Action Plan for Major Crisis Situations

4)Develop a press release if necessary.4)Develop a press release if necessary.

5)Notify employees and affected customers if 5)Notify employees and affected customers if necessary.necessary.

6)Refine initial action plan and initiate;6)Refine initial action plan and initiate;

*Keep daily log of occurrences*Keep daily log of occurrences

*Send samples to laboratories if needed. *Send samples to laboratories if needed.

*Decide if a recall is needed, to what extent *Decide if a recall is needed, to what extent

and who will facilitate the recall.and who will facilitate the recall.

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Action Plan for Major Crisis Situations

7)Continue meeting of CMU until crisis is over.7)Continue meeting of CMU until crisis is over.

*Marketing/ sales should be gathering statistics as *Marketing/ sales should be gathering statistics as

to how the crisis hurt the company and develop to how the crisis hurt the company and develop

a plan to counter negative publicity.a plan to counter negative publicity.

*No CMU member will talk to anyone outside the *No CMU member will talk to anyone outside the

CMU except the spokesperson. CMU except the spokesperson.

*Continue to work with investigative agencies *Continue to work with investigative agencies

(FSIS, FDA, FBI) if needed,(FSIS, FDA, FBI) if needed,

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Product Tampering/ Adulteration

This section should include those areas This section should include those areas where the food has been tampered with where the food has been tampered with after it has left the production facility.after it has left the production facility.

Remember the Tylenol case 13 years ago Remember the Tylenol case 13 years ago when someone added poison to bottles of when someone added poison to bottles of Tylenol while it was on the store shelves?Tylenol while it was on the store shelves?

This case, almost single-handedly lead to This case, almost single-handedly lead to tampering-resistant packaging. tampering-resistant packaging.

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Product Tampering/Adulteration

The President of Tylenol went on television The President of Tylenol went on television and expressed concern for the victims and and expressed concern for the victims and said how bad it was for this to happen to a said how bad it was for this to happen to a company whose purpose it was to help company whose purpose it was to help people suffering from illness.people suffering from illness.

This was the perfect response and prevented This was the perfect response and prevented Tylenol from losing Tylenol from losing anyany market share. market share.

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Product Tampering/ Adulteration

Could something like this happen to your Could something like this happen to your product?product?

How should the CMU respond?How should the CMU respond? Bioterrorists could tamper with your Bioterrorists could tamper with your

product in the processing plant, during product in the processing plant, during distribution and on store shelves. How distribution and on store shelves. How should the CMU respond?should the CMU respond?

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FOOD POISONING

False claims are made all the time by False claims are made all the time by consumers who ate your product and got consumers who ate your product and got sick. Some are just looking for coupons or sick. Some are just looking for coupons or some type of monetary compensation.some type of monetary compensation.

Some claims may be very real and it is best Some claims may be very real and it is best to respond quickly and proactively before it to respond quickly and proactively before it gets blown out of proportion.gets blown out of proportion.

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Steps to be taken in cases of Food Poisoning

1)Assemble the CMU to discuss the situation and 1)Assemble the CMU to discuss the situation and appoint a group to visit the patient, the doctor and appoint a group to visit the patient, the doctor and any health officials involved. Notify any government any health officials involved. Notify any government agencies (FSIS, FDA, FBI etc) if appropriate. Send agencies (FSIS, FDA, FBI etc) if appropriate. Send out samples to an outside laboratory if appropriate.out samples to an outside laboratory if appropriate.

2)The laboratory analysis should determine the type of 2)The laboratory analysis should determine the type of bacteria involved. The CMU will meet to determine bacteria involved. The CMU will meet to determine if the problem is due to the processing facility, if the problem is due to the processing facility, consumer neglect or a false claim on the part of the consumer neglect or a false claim on the part of the consumer.consumer.

3)In these types of cases, suppress media coverage.3)In these types of cases, suppress media coverage.

66Photo courtesy of USDA

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Food Poisoning

One final word on food poisoning cases. One final word on food poisoning cases.

Each plant and company must determine how they Each plant and company must determine how they will handle reported food poisoning cases. If the will handle reported food poisoning cases. If the CMU response to a food poisoning case is too CMU response to a food poisoning case is too slow and if the problem is real, many people may slow and if the problem is real, many people may become sick before you initiate a recall. However, become sick before you initiate a recall. However, if you initiate a recall when no real problem exists, if you initiate a recall when no real problem exists, you risk possible negative publicity when it wasn’t you risk possible negative publicity when it wasn’t warranted. warranted.

68Listeria Monocytogenes

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Bioterrorism

We have all heard of the threat that bioterrorists We have all heard of the threat that bioterrorists could possibly get into the United State’s food could possibly get into the United State’s food supply channel although no specific attacks have supply channel although no specific attacks have actually taken place. actually taken place.

Terrorists could conceivably poison the incoming Terrorists could conceivably poison the incoming raw materials in our food plants, poison the raw materials in our food plants, poison the finished product in the plant or poison it while on finished product in the plant or poison it while on the retail shelves which would fall under the topic the retail shelves which would fall under the topic of tampering/adulteration.of tampering/adulteration.

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BIOTERRORISM

The FDA has recently published guidelines for The FDA has recently published guidelines for bioterrorism in our food supply and can be found bioterrorism in our food supply and can be found on the following websites;on the following websites;

*Food Producers, Processors and Transporters; Food *Food Producers, Processors and Transporters; Food Security Preventive Measures Guidance- can be Security Preventive Measures Guidance- can be found at found at www.cfsan.fda.gov/~dms.secguid6.htmlwww.cfsan.fda.gov/~dms.secguid6.html..

*Retail Food Store and Food Service *Retail Food Store and Food Service Establishments; Food Security Preventative Establishments; Food Security Preventative Guidance-can be found at Guidance-can be found at www.cfsan.fda.gov/~dms/secguid5.htmlwww.cfsan.fda.gov/~dms/secguid5.html..

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BIOTERRORISM

Every food processing plant should get these Every food processing plant should get these publications, study them and develop an action publications, study them and develop an action plan for food security.plan for food security.

These guidelines should also be reviewed by the These guidelines should also be reviewed by the CMU and action plans developed to counteract the CMU and action plans developed to counteract the effects if something were to happen.effects if something were to happen.

After reviewing these guidelines, the CMU may After reviewing these guidelines, the CMU may possibly alter the way they approach crisis possibly alter the way they approach crisis management.management.

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RECALLS

Recalls are by far the most important Recalls are by far the most important crisis one will ever facecrisis one will ever face

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PRODUCT RECALLS

This series on recalls is to be used as a guide for This series on recalls is to be used as a guide for the teaching of the fundamentals involved in the teaching of the fundamentals involved in recalls but because of the seriousness, varying recalls but because of the seriousness, varying codes by various agencies (USDA vs FDA), type codes by various agencies (USDA vs FDA), type of product and method of processing, every food of product and method of processing, every food processing plant should have a recall policy that is processing plant should have a recall policy that is developed after careful consideration of the developed after careful consideration of the regulations, product mix, customer base, method regulations, product mix, customer base, method of processing and distribution etc.of processing and distribution etc.

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Product Recalls

Recalls should be initiated by a company Recalls should be initiated by a company and are classified into one of three and are classified into one of three categories;categories;

*Product Recall*Product Recall

*Market Withdrawal*Market Withdrawal

*Stock Recovery*Stock Recovery

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PRODUCT RECALL

A Product Recall is a voluntary action by a A Product Recall is a voluntary action by a company that marketed the product and is defined company that marketed the product and is defined as removing from the market and distribution as removing from the market and distribution channels those products that are adulterated or channels those products that are adulterated or misbranded to the extent that it is subject to seizure misbranded to the extent that it is subject to seizure under current FDA or USDA policy and guidelines. under current FDA or USDA policy and guidelines. Product recalls are an efficient and effective means Product recalls are an efficient and effective means of removing sizable products from the marketplace. of removing sizable products from the marketplace. The alternative to recalls is the seizure or other The alternative to recalls is the seizure or other legal actions by regulatory agencies.legal actions by regulatory agencies.

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MARKET WITHDRAWAL

Market Withdrawal is the situation where Market Withdrawal is the situation where no violation is involved or the violation is no violation is involved or the violation is minor and not subject to seizure under minor and not subject to seizure under current USDA or FDA policy and current USDA or FDA policy and guidelines (e.g. poor product quality)guidelines (e.g. poor product quality)

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STOCK RECOVERY

Stock Recovery is a situation where none of Stock Recovery is a situation where none of the product has left the direct control of the the product has left the direct control of the manufacturer or primary distributor. This manufacturer or primary distributor. This type of action would be a product recall or type of action would be a product recall or market withdrawal if the product were in market withdrawal if the product were in the distribution channels.the distribution channels.

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Classifications of Recalls

FDA and USDA classifies recalls into one FDA and USDA classifies recalls into one of three classes.of three classes.

*Class I*Class I

*Class II*Class II

*Class III*Class III

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Class I Recalls

In a CLASS I recall, it is an emergency In a CLASS I recall, it is an emergency situation involving the removal from the situation involving the removal from the market those products which the market those products which the consequences are immediate or long-term, consequences are immediate or long-term, life threatening and involve a direct cause-life threatening and involve a direct cause-effect relationship. An example would be effect relationship. An example would be botulism toxin in food. Top priority must be botulism toxin in food. Top priority must be given to the complete and immediate recall given to the complete and immediate recall of the products to the consumer level.of the products to the consumer level.

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Class II Recalls

CLASS II recalls are situations where the product CLASS II recalls are situations where the product may cause temporary adverse health consequences may cause temporary adverse health consequences or where the probability of serious health or where the probability of serious health consequences are remote. The most common Class consequences are remote. The most common Class II recalls are undeclared use of FD&C #5 coloring II recalls are undeclared use of FD&C #5 coloring and products slightly exceeding tolerance levels and products slightly exceeding tolerance levels for toxic substances. FDA and USDA requires for toxic substances. FDA and USDA requires product to be recalled to the retail level completely product to be recalled to the retail level completely and promptly.and promptly.

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Class III Recalls

CLASS III recalls are those in which the CLASS III recalls are those in which the consequences to life (if any) are removed or consequences to life (if any) are removed or non-existing. Products are recalled because non-existing. Products are recalled because of adulteration or misbranding not involving of adulteration or misbranding not involving a health hazard. The most common example a health hazard. The most common example are labeling violations. FDA and USDA are labeling violations. FDA and USDA generally requires that the product be generally requires that the product be recalled only to the wholesale level.recalled only to the wholesale level.

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Why Should A Company have a Recall Policy?

Protect customer and consumer safetyProtect customer and consumer safety Protect the assets of the companyProtect the assets of the company Comply with applicable laws and Comply with applicable laws and

government regulationsgovernment regulations Remove unacceptable or questionable Remove unacceptable or questionable

products from the market at minimum cost products from the market at minimum cost and inconvenience to the customer and and inconvenience to the customer and consumer.consumer.

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What are the Objectives of a Recall Policy?

Locate the productLocate the product Remove the product from the marketRemove the product from the market Provide accurate information to government Provide accurate information to government

agencies and consumers/customers when agencies and consumers/customers when appropriate.appropriate.

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HOW A RECALL WORKS

A complaint is issued.A complaint is issued. The CMU or recall team is convened to The CMU or recall team is convened to

collect informationcollect information Plant Manager or QA Manager decides if a Plant Manager or QA Manager decides if a

recall is needed.recall is needed. A recall action plan is developed and tasks A recall action plan is developed and tasks

assigned.assigned. The recall is started.The recall is started.

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Complaints

Every day, a company has a constant stream of Every day, a company has a constant stream of indicators from customers, quality control lab tests, indicators from customers, quality control lab tests, government agencies and internally that something government agencies and internally that something may be wrong.may be wrong.

Managers are trained and experienced into what Managers are trained and experienced into what clues may be signs of a major problem. For clues may be signs of a major problem. For example, if a customer complains about a product, example, if a customer complains about a product, they may just want coupons or free samples but if a they may just want coupons or free samples but if a doctor calls about a sick person who ate your doctor calls about a sick person who ate your product or if the USDA calls about something, it product or if the USDA calls about something, it should be taken seriously.should be taken seriously.

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Assembly of the Team

When the plant manager or QA manager hears of When the plant manager or QA manager hears of something of significance, the CMU or recall team something of significance, the CMU or recall team is assembled. is assembled.

This team may or may not be the same as the This team may or may not be the same as the CMU team because the recall team needs to CMU team because the recall team needs to include a broader range of managers.include a broader range of managers.

The recall team should consist as a minimum of The recall team should consist as a minimum of the plant manager, quality control manager, sales, the plant manager, quality control manager, sales, distribution, customer service etc.distribution, customer service etc.

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The Recall Team

The recall team is called together to collect The recall team is called together to collect information about an incident. information about an incident.

*Is the source of information credible?*Is the source of information credible?

*What type of recall would this be?*What type of recall would this be?

*How widespread is the problem?*How widespread is the problem?

*Any facts bearing on the incident that *Any facts bearing on the incident that

need to be discussed.need to be discussed.

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Action of the Recall Team If the information collected is decided to be of significance;If the information collected is decided to be of significance; 1)Suspected product in the warehouse should be 1)Suspected product in the warehouse should be put on “internal hold”. put on “internal hold”. 2)If appropriate, government agencies should 2)If appropriate, government agencies should be notified.be notified. 3)Stores/ Customers should be notified of the 3)Stores/ Customers should be notified of the situation telling them the product name and situation telling them the product name and number, product size, bar codes numbers if number, product size, bar codes numbers if used, code dates effected and estimated used, code dates effected and estimated quantities etcquantities etc

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Actions of the Recall Team

4)Initiate the pickup of suspected or recalled 4)Initiate the pickup of suspected or recalled product from stores.product from stores.

5)Keep accurate records of the amount of 5)Keep accurate records of the amount of product recovered.product recovered.

6)Dispose or rework recalled product.6)Dispose or rework recalled product.

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Product Recalls

This is obviously a very simplified version of This is obviously a very simplified version of what would happen.what would happen.

Anyone who has ever survived a recall can tell Anyone who has ever survived a recall can tell you, it is a gut-wrenching experience and one to you, it is a gut-wrenching experience and one to be avoided at all costs. be avoided at all costs.

Because the numerous variables between products, Because the numerous variables between products, manufacturing methods, government regulations manufacturing methods, government regulations and other variables, one is best advised to have a and other variables, one is best advised to have a recall policy and plan written up in detail.recall policy and plan written up in detail.

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STEP #4; Develop and Distribute a Crisis Management Booklet to

all Responsible Parties

This booklet should include the CMU members This booklet should include the CMU members and their responsibilities, action plans for various and their responsibilities, action plans for various crisis situations from local crisis to recalls with crisis situations from local crisis to recalls with appendices with templates for every conceivable appendices with templates for every conceivable crisis and every possible telephone number crisis and every possible telephone number needed. needed.

Get the booklet into the hands of every person in Get the booklet into the hands of every person in the plant who could use it.the plant who could use it.

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The Appendices

The appendices is a good place to have a number The appendices is a good place to have a number of things so they are all in one place and easily of things so they are all in one place and easily obtained. These include detailed templates for obtained. These include detailed templates for every possible crisis that could happen along with every possible crisis that could happen along with telephone numbers..telephone numbers..

When you are in a mist of a crisis, you don’t want When you are in a mist of a crisis, you don’t want to be going through your file cabinet looking for to be going through your file cabinet looking for some document or fumbling around looking for a some document or fumbling around looking for a telephone number.telephone number.

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Telephone Numbers

It is a good idea to have several pages of relevant It is a good idea to have several pages of relevant telephone numbers in the appendix.telephone numbers in the appendix.

Some necessary numbers include CMU work and Some necessary numbers include CMU work and home numbers, FDA, USDA, FBI, fire home numbers, FDA, USDA, FBI, fire department, police department, local emergency department, police department, local emergency preparedness group, hospital, ambulance service, a preparedness group, hospital, ambulance service, a local chemical spill organization, natural gas local chemical spill organization, natural gas company, water company, etc. Your CMU company, water company, etc. Your CMU committee can brainstorm other organizations that committee can brainstorm other organizations that needed to be included.needed to be included.

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CONCLUSIONS

Even though a food related crisis cannot be Even though a food related crisis cannot be prevented, it can be controlled.prevented, it can be controlled.

This series has gone through the steps in crisis This series has gone through the steps in crisis management and briefly discussed considerations management and briefly discussed considerations for a crisis management team to consider when for a crisis management team to consider when developing a crisis management plan.developing a crisis management plan.

The types of recalls and a simplified recall plan The types of recalls and a simplified recall plan have been discussed.have been discussed.

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