Protecting Fido:Recall Preparedness for the Pet Industry

Your guide to a safe, effective, compliant product recall

2Protecting Fido: Recall Preparedness for the Pet Industry

Background

They are included in many family portraits, receive gifts for birthdays and holidays, and even escort some brides down the aisle. Most pet owners – or pet parents, as many prefer to be called – will tell you their pets are family.

It’s no surprise that spending on pet products in the United States has nearly tripled in the last 20 years1, continuing to grow even during the Great Recession that began in 2007.

So when a recall involving pets occurs, it is no insignificant matter to the humans who care for them. Companies must recognize the conse-quences serious safety issues can carry and take steps to prevent them. And when a recall does become necessary, companies should be ready to respond quickly and effectively – or face serious backlash from the press and public. With new rules taking effect regarding the manufacturing and labeling of pet food, the need to develop and update both prevention and recall preparedness plans is more crucial than ever.1americanpetproducts.org

3Protecting Fido: Recall Preparedness for the Pet Industry

The Quibble over Kibble

Pet products such as collars and crates are rarely recalled, in part because they are subject to few regulations. The Consumer Product Safety Commission has authority to mandate such recalls, but only when they could endanger a human – not an animal.

While some have called for additional rules, manu-facturers say they already implement strong safety standards on a voluntary basis.

Pet food recalls are a different story. Several high-pro-file recalls of pet foods that caused illness and even deaths in recent years put pet food safety in the spotlight, including a 2007 issue that affected doz-ens of brand names. In the last five years, recalls have continued to plague the industry. Since 2011, there have been more than 360 recalls of food and pharmaceuticals for animals, including both pets and livestock, totaling more than 76.5 million units. Class I situations – the most serious type of recall – made up the highest percentage of both recalls and recalled units. Bacterial contamination was the leading cause of recalls, mostly due to salmonella. Ingredients or chemicals that exceeded FDA-approved levels ac-counted for the second highest number of recalls.

Pet food and other animal feed products are subject to both federal regulations and state laws. Like food meant for humans, the Food and Drug Administra-tion requires that pet food products be “safe to eat, produced under sanitary conditions, free of harmful substances, and truthfully labeled.” However, there are fewer regulations when it comes to animal foods. For example, no specific rules are in place regarding the labeling of organic foods for pets. One of the final rules of the Food Safety Modernization Act (FSMA) imposes new requirements that both pet and livestock feed manufacturers must follow. It mandates that companies follow Current Good Manufacturing Practices (CGMPs), perform a hazard analysis, and implement risk-based preventative controls. It also requires that companies develop a recall plan.

4Protecting Fido: Recall Preparedness for the Pet Industry

Grooming Recall Teams

Creating and maintaining a recall plan – and then testing that plan with mock recalls – should be a top priority of most companies, including those that manufacture pet food. The plan should include a designated recall management team with specific responsibilities.

This will help hold individuals accountable for their role in effective recall execution. There should also be a process in place for fact gathering to determine the root cause of the issue and identify where the product is being sold and how to get it off of shelves and out of homes and back to the company for stor-age and ultimate destruction.

Companies must also have a detailed plan for de-termining the nature of the health hazard, with guidelines for actions and remedies necessary de-pending on the severity of the risk. There should also be a procedure for notifying the regulatory agencies

involved and communicating the issue to retailers, distributors, the media, and consumers. Finally, com-panies should have a detailed method for closing out the recall, which depends on detailed data for regulatory reporting.

A major factor to consider with a recall involving pets is contact center capabilities. Pet safety concerns are catnip for the media, and intense coverage often leads to a deluge of calls, even from owners whose pets do not demonstrate any signs of illness or who have never purchased the brand in question.

5Protecting Fido: Recall Preparedness for the Pet Industry

The Right Remedy for Rover

When it comes to recall remedies, companies have several options available. With pet food, as with other food products, a full refund or coupon for replacement is a common option. When a pet food issue causes serious illness requiring veterinary care, many pet owners will appeal for reimbursement of those costs.

The FDA does not have the authority to enforce these requests, so such action is optional on the part of manufacturers. However, many companies have faced lawsuits from pet owners whose animals became ill from recalled pet food, and some of those companies ultimately chose to settle claims.

The publicity surrounding such claims can spoil an otherwise respected brand, and no matter the out-come of court cases, consumers who have a bone

to pick with pet food companies often take to the internet to voice their frustration over the situation. Entire blogs and Facebook groups are dedicated to pet food safety issues – some of which have thou-sands of “likes.” When evaluating claims, companies should consider whether offering reimbursement for veterinary visits and other remedies that go beyond standard reimbursement would help keep them out of the doghouse with consumers.

Murphy’s Paw: Preparing for the Inevitable

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A recall involving man’s best friend can be a company’s worst nightmare. People have a passion for their pets, and any issue that endangers them can provoke strong reactions.

But a recall is bound to happen eventually, and while the steps involved in ensuring recall read-iness may sound overwhelming, dealing with a recall on the fly is even more daunting. Companies that prepare in advance can respond quickly and efficiently – something consumers expect when their beloved pets are at stake.