Information can spread at an unprecedented speed, especially in the hands of consumers. Here’s what you need to know before an issue or crisis hits.
The evolution of digital communication and social media has forever changed how consumers react to the powerful images that inevitably emerge in crisis situations. In today’s digital world, business policies and procedures need to recognize the potential impact of information that can travel at an unprecedented speed. Understanding what is being said about your company or brand is fundamental, and companies have responded by adding head count, entire departments or using media tracking services that monitor the company’s name and flag it when associated with potentially negative stories.
Consumer affairs organizations play a key role in taking appropriate actions during the emergence of an issue so that it doesn’t become a crisis. Should a serious issue such as a recall occur, consumer affairs can be a primary conduit of the company’s message.
Crisis management plans and call center training manuals should be periodically evaluated and refreshed to reflect emerging issues. Several approaches are available to predict future issues, so that proper strategies can be developed to quickly and effectively counter negative responses and mitigate risk, wherever and whatever the source. A comprehensive review of potential issues may include these issues.
- Ingredient sourcing has become an area of controversy. GMO, or genetically modified organism, and country-of-origin labeling has exposed formulated products to intensive scrutiny.
- Camera on mobile phones have turned everyone with a cell phone into a photographer. If a consumer finds an objectionable product on the shelves and starts blogging about it, your label may be prominently displayed in a photo or video.
- Incidents may involve a competitive brand, but all of the same product type, e.g. all peanut butter, airbags or ground beef, may experience the fallout.
- Food scandals outside your normal sphere of sourcing and distribution may prompt rumors about your products. Does your honey supplier source from China? Could you be implicated in their ongoing antibiotic scandals?
- Consider topics that might evoke strong emotional reactions, such as stories of illness and death among children, elderly, immune-compromised and pregnant women. Injuries or fatalities related to your industry’s sector or products and the associated response should be incorporated into complaint and crisis management procedures.
There are significant regulatory considerations in the management of consumer complaints and are currently top of mind for those in the Food and Drug Administration (FDA) regulated food and beverage industries.
- Large companies must comply with the Food Safety Modernization Act’s (FSMA) Preventive Controls for Human Food in September of this year. Once preventive controls are established, verification activities are required to ensure they are consistently implemented and effective. While the final rule does not establish a requirement to review consumer complaints as a verification activity, the FDA does encourage such a review to improve the facility’s food safety system.
- The FDA has had unprecedented records access since 2012, under the FSMA Interim Final Rule on Records Access. In the past, the FDA needed to have “credible evidence” that a food would cause adverse health consequences in order to request access to the records—including consumer complaint records. Today they need only have “reasonable belief.”
- Historically, for a food associated with a serious adverse health consequence or death, the FDA was authorized to access records directly related to the implicated foods only. Today they have the authority to view and copy the records of other foods that may have been impacted, including complaint and adverse event records.
- The FDA expects to see closure of complaints in a timely fashion, with the appropriate actions taken if complaint records indicate meeting a threshold for a potential recall. Complaint handling procedures should include escalation triggers with targeted response times.
- Electronic records must also be retained and protected according to a company’s established records retention policies, meeting consumer privacy act requirements as well as complying with such diverse regulations as California’s Electronic Discovery Act and comparable legislation in other states. This law states that in the event of threatened or actual litigation, email or other electronic documents may not be destroyed.
- FSMA’s Focused Mitigation Strategies to Protect Food Against Intentional Adulteration highlights the need across all industries for robust procedures and training in the event a product tampering or extortion threat is received. Do all call center agents know how to handle this call, email or text? Are there clear steps and current contact information available to all stakeholders?
Companies should enhance traditional crisis communications plan with specific strategies to handle online crises and facilitate the rapid release of messaging. The single most important part of your digital crisis plan will be to identify who “owns” online communications in a crisis. Interdepartmental disputes between marketing, public relations and consumer affairs departments will only be distracting when you face a crisis online.
- Script templates, dormant interactive voice response architecture and dark websites are useful tools to quickly react to crises. Dark site webpages are developed and fully functional but not accessible to the general public until activated. Identify industry related issues such as outbreaks and recalls to construct appropriate pages. Specific information may then be easily populated and rapidly deployed. Remember, your company’s website is one of the first Internet search destinations for most consumers.
- Proactive engagement with social media might be one of the best ways to develop a solid reputation before crisis strikes. Fielding “Q&A” pages on your website, engaging in active discussion to dispel false rumors, or offering transparency may guide consumers to seek answers directly from the source—your company.
- Consider developing a clear policy that encourages your employees to learn and use social media. This policy could demonstrate best practices for differentiating between personal and professional activities and establish clear guidelines for appropriate commentary.
A well-trained and connected workforce is one of the best resources for correcting misinformation and reclaiming your online narrative. As a guardian of your company and its brands, understanding and expanding the lines of digital communication may enable you to maintain brand trust in the face of a crisis.
Mary Ann Platt is the executive vice president of RQA, Inc. and president of CNS/FoodSafe. Following her position as vice president of global manufacturing for Monsanto’s nutrition and consumer products division, she joined RQA in 1999. With more than 40 years of food and consumer products industry experience, she is a member of SOCAP, the International Association for Food Protection, the Institute of Food Technologists and the American Society for Quality. She is a frequent speaker and contributor to publications in the area of crisis management and operational excellence.