Client: Branded Manufacturer
Industry: Food Manufacturing
Situation: This issue escalated from a consumer allegedly finding a metal bolt in a ready-to-eat packaged food manufactured by the client, and complaining to his local environmental health officer (EHO). The consumer helpline that had received the complaint liaised with the client’s quality department which initiated an investigation, in order to brief an external consultancy X to whom they had (at that time) fully outsourced both consumer and enforcement issues.
In response the complaint was investigated and a response given on behalf of the client by consultancy X; however, the response did not fully demonstrate that the company had “reasonable precautions and due diligence” in place, because the quality department had been unable to provide a full set of records for the routine checks that should have been conducted according to the documented procedures.
The investigating EHO identified these gaps and made numerous requests to Consultancy X to provide the missing records, and Consultancy X, in turn made numerous requests without success to the clients’ quality team. Unfortunately, this delay resulted in a dissatisfied EHO, who, as he was empowered to, made an unannounced visit to the factory floor.
Upon conducting his investigation with his colleagues the EHO found nuts and bolts missing in several places on the production line, with one bolt actually falling into his hands during the inspection – all of the exposures were recorded on camera !
A further visit to the engineering stores only served to fuel the EHOs concerns that processes were not being followed. The Client was advised by the EHO that they would be liaising with the Authority’s lawyers (regarding the complaint and the EHO investigation of it) and would be in touch!
Solution: At this point the Client took guidance from our team – we advised the client of the immediate shortcomings, and that whilst the client was on the “back foot”; that the right response, speedily put together might retrieve the situation. Under our instruction, one of our associates immediately began to conduct an independent review and gap analysis of the client’s food safety management; and pending the outcome of that we began to look at the positive aspects of the client’s “due diligence” in order to build a narrative around that.
Outcome: The narrative that formed suggested that the client’s system was fundamentally sound; and that the independent review being conducted and actions arising from it would result in improvement. The credibility of our team, and its enforcement insight was invaluable in presenting the facts in a way that lead to a favourable, informal outcome, from seemingly difficult circumstances.
We liaised with the clients in-house legal team; quality department; engineering; and consumer relations teams to optimise their processes for handling complaints, investigations, and incident management.
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