Food recalls are inevitable…but not all of them!

Vince Shears, MD RQA Group“Having seen first-hand many companies experience product recalls and knowing the financial and reputational damage they can cause, I wanted to see if it was possible to prevent at least some of them from happening. Last year, I identified a specific type of product recall which I refer to as Never Events; a term used in the health service. I identified several possible causes of avoidable recalls. I am now narrowing the focus further to look specifically at allergen-related recalls where food items have the wrong label or where the wrong product is put into the pack. With a small amount of effort, I believe these types of recalls can be entirely prevented. Read on to find out more about Never Event product recalls, how common they are and how they can be avoided.”

Vince Shiers Ph.D., Managing Director, RQA Group.

Click here to download and read this article as a PDF, or read on below
Food product recalls are a fact of life for food manufacturers globally. It doesn’t matter how good the food safety systems and controls are, recalls still happen.

We know that recalls happen in the largest companies that have highly comprehensive control systems and expert food safety teams along with enviable budgets. Even this does not catch every fault all the time. A quick google search on “<company name> and product recall” will show you that many of the largest companies have had recalls this year. No system is perfect. But if the biggest companies have recalls, what chance do SMEs have? Humans make mistakes and take short cuts. If training is reduced due to budget cuts, or staff levels are reduced due to the pandemic,  errors can occur. No food company should consider a recall as a remote possibility.

What can be done to reduce recalls?

The answer is keep doing all the good work on food safety and recall prevention but increase the focus on recalls that are easiest to prevent. I call these “Never Event” recalls and they are the low hanging fruit. A little effort could make a big difference in reducing the possibility of a food company having a product recall. I have borrowed the term “Never Event” from the UK health sector and applied it to the food industry. Click here to read my original article.

What is a Never Event?

In the UK National Health Service (NHS) examples of a Never Event include a surgical intervention performed on the wrong patient or wrong site (for example wrong knee, wrong eye). Criteria for classifying a Never Event are:

  1. They are wholly preventable
  2. Each “Never Event” type has the potential to cause serious patient harm or death
  3. The category of “Never Event” has occurred in the past…and a risk of recurrence remains
  4. Occurrence of the “Never Event” is easily recognised and clearly defined
What food recalls ARE avoidable?

In the food industry, a Never Event product recall could be when the wrong label is put on a food product or the wrong product is put into the pack. Both of these examples may result in an allergen safety risk and meet all four of the above criteria.

Why aren’t all recalls Never Events?

Using the above criteria for classifying a Never Event, there are many recalls that do not fit that definition. For example, many recalls would not be considered “wholly preventable” or “easily recognised”.  A contaminated ingredient with trace levels of contamination is often difficult to detect and so neither wholly preventable nor easily recognised.

How many Never Event recalls are there?


The short answer is a lot so it’s a great opportunity for food companies to reduce their recall risk.  In the UK, these Never Event product recalls  accounted for, on a monthly basis, between 40 and 100% of all allergy alerts reported by the UK Food Standards Agency (Jan – Aug 2020). This is 70% of all allergy alerts over that time period. From June to December 2019, it was 72%, so a very consistent and high level.




Never Event product recalls involving labelling errors accounted for, on a monthly basis, between 6 and 21% of all food recall events reported by the USFDA between January and August 2020. The average over the period was 10% of all recall events. Last year, Aug – Dec 2019, 16% of recall events could be classed as Never Events. However, this is likely to be an underestimate of the total number of Never Events as we have only included recall events where the cause is clear. There are others that we have not included where it is not possible to assess the specific cause of an allergen-related recall.

What can you do to reduce recalls?

Anyone who has been involved in a product recall knows how much time, energy, stress, and cost is involved in managing them, not to mention the impact it can have on your brand. Put some of that time into preventing them…

  1. If wrong label or wrong product has even the slightest risk of occurrence in your company, you need to take action.
  2. Make senior colleagues aware of the risk of these events happening in your company. If you are in a senior position, find out if, and how, these risks are managed.
  3. Read our original article that includes a 12-point plan to implement a “Never Event” principle.
  4. Contact RQA Group to see how our expert consultants can help reduce your Never Events risks on: or call +44 (0)118 935 7242.