How To Conduct a Mock Recall of Your Cannabis Products
Recalls are the single biggest threat to the profitability of all cannabis manufacturing businesses, but when there are whispers of a product recall in the cannabis industry, there is much more than just dollars and cents at stake. That’s why every facility should have a mock recall plan in place.
While profit margins and PR nightmares are the most concerning outcomes for cannabis brands, what most people don’t realize is that a recall can also negatively impact the industry as a whole. Since the cannabis market is still in its infancy, even the smallest product recall can have a damaging impact on the industry’s overarching image. Similar to how consumers tend to doubt the safety of romaine lettuce after countless recalls, they now doubt whether or not their local dispensary is selling moldy cannabis flower. In this article, we’ll lay out mock recall guidelines and specific steps for conducting an effective mock recall exercise.
Cannabis Industry Recalls
In general, recalls will take place when there is a legitimate public health concern. In the cannabis industry, most recalls are relatively small since medical and adult-use license holders are only allowed to distribute their products throughout the state they are licensed. In these instances, cannabis companies who have the unfortunate task of initiating a recall will likely only have to deal with their state regulators. However, federal regulatory agencies like the FDA are getting more involved with multi-state CBD recalls. Since 2015, the FDA has forced several brands to recall their products due to false health claims and mislabeled products. Even though the FDA has not established guidance or regulations on CBD products, the lack of a regulatory framework does not mean a lack of recalls.
Why Your Facility Needs a Mock Recall Plan
Conducting a mock recall is not only a requirement for CSQ Certification, but it is also an important part of your facility’s crisis management planning as well. During COVID-19, many companies faced the harsh reality that they were not prepared for a real-life crisis. By creating a mock recall plan, and then conducting a mock recall at least annually, your cannabis business is taking the appropriate steps to prepare for the worst. If and when a real recall does occur, your business is ready to act fast, minimize the loss of profits, and save face with the public. Follow the steps below to conduct an effective mock recall.
Mock Recall Guidelines
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Gather Recall Team: Your recall team should already be established before you perform your mock recall and should be composed of various individuals and departments, such as, senior management, safety and quality team, production employees, legal counsel, external consultants, etc. For smaller companies or companies that experience high turnover, it might make more sense to establish a Recall Coordinator whose responsibility is to assign roles and responsibilities to key staff they select to be a part of the recall team.
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Discovery: The second step in a recall situation is the discovery of a potential product problem. Discovery can happen in many ways. For example, supplier notification, internal or external lab discovery, employee observation, consumer complaint, or regulatory notification are all possibilities..
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Recall Decision: During the recall decision step, the recall team will need to collect and analyze all information and data regarding the product that may be recalled. This includes assessing the scope of the product that should be recalled (i.e., amount and type of product). From there, the recall team will need to determine the depth of the recall, for example:
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Wholesale-level: The product has been distributed to a warehouse or distribution center and is not under the direct control of the company.
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Retail-level: The product has been received by retailers for sale to consumers.
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Consumer-level: The product has been sold directly to consumers.
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Notification: Once the scope of the recall has been determined, it is now the recall team’s responsibility to notify the appropriate parties. This may include customers/patients, retailers, regulatory agencies, and the company’s certification body.
The method of notification to appropriate parties shall be determined by the severity of the recall. The quickest way to reach people is by telephone. In these instances, a script should be prepared for the individuals making the calls to ensure that the caller provides clear information on the product, the problem, and the next steps to take. Even if a company calls all of the appropriate parties, a written recall notice shall be provided to all appropriate parties who received the recalled product(s). After notifications are sent out, the recall team should confirm the receipt of the notice of recall with all parties.
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Hold and Disposition: Once notifications are sent to the appropriate parties, the recall team should make all reasonable efforts to remove the affected product from commerce. Any products that are still in the company’s control (i.e., in inventory, transit, or offsite distribution) should be quarantined and held. If products are returned to the company from retailers or customers, then those products shall be held in quarantine as well.
In some instances, the affected product may not need to be destroyed (i.e., mislabeled products). In these situations, the company shall perform a risk assessment along with regulatory and legal guidance to determine if products may be reworked or repackaged. Products that cannot be reworked or repackaged due to health concerns shall be destroyed appropriately according to local regulations.
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Evaluation: Once all of the product has been accounted for and the appropriate disposition has been made on in-house and returned products, the recall team shall evaluate the performance of their mock recall to determine if it was effective. If there are any gaps identified during the mock recall process, then the recall team should determine the root cause and implement corrective actions to improve the overall recall process.
Why CSQ Certification Makes Good Business Sense
Getting certified to one of CSQ’s standards does not guarantee that a company will not have a recall, although the likelihood of a recall is significantly reduced when comparing certified companies to non-certified companies. However, companies certified to CSQ will be certified for having the appropriate policies and procedures in place for recalls. CSQ certification helps ensure that companies that have a recall incident are prepared and can mitigate the potential damage of a recall on that company’s brand, profitability, and the industry as a whole.
