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Crisis Communications Plan

Developed by Dezenhall Resources
April 2003

What is a Crisis?

A crisis is an event, action or allegation that has the potential for significant, lasting negative impact on NAMA and the milling industry.  A crisis catalyst – real or perceived – has the potential to result in one or more of the following:

  • Damage to NAMA’s and/or the industry’s credibility and reputation
  • Significant impacts on the business of milling
  • Significant legal liability
  • Legislative or regulatory threats
  • Endangerment of the environment, or the health and safety of milling workers or the public

NAMA’s Role in a Crisis

NAMA will be guided by the following protocols:

  1. NAMA will engage in crisis situations that clearly and directly affect, or may cause harm to, the milling industry — based on the five criteria listed above under “What is a crisis?”
  2. NAMA will engage in crisis management activities when it is clear that the event has industry-wide implications and/or news media or government reactions would affect the entire industry, versus an event that only affects one member and/or will be confined to a limited market.
  1. NAMA has the authority to communicate and take actions within the United States. It will seek member approval before it initiates any actions in regions or markets outside the U.S.
  1. NAMA will stick to representing the industry as a whole, and will not speak directly for a member company. When contacted by the news media, government officials or others about individual member incidents, NAMA will refer the calls directly to the member. NAMA may, as appropriate, serve as a conduit or refer to public statements made available by member companies, if the incident has industry-wide implications.
  1. NAMA will treat all information shared by its membership confidentially, and will not share it with anyone without prior consent.
  1. NAMA will be careful not to replicate unnecessarily the efforts of other food industry associations, particularly on issues that affect other sectors well beyond the milling industry.

NAMA’s Crisis Team: Roles and Responsibilities

Staff functions during a crisis and outside resources that may be called upon. Any member can convene the crisis team.

  • Team Leader –  Jim Meyer – Jim will direct the activities of the crisis team, make or approve the major decisions, approve expenditures and allocate resources, liaison with NAMA’s board of directors, and serve as the primary spokesperson.
  • Alternate Crisis Team Leader – Jim Bair – Jim will serve as alternate crisis-team leader in Mary’s absence.
  • Government Outreach – Jim Bair – Jim is responsible for outreach to Capitol Hill, USDA, FDA, EPA and other relevant government agencies.
  • NAMA Media Liaison – Terri Long – Terri will serve as the primary news media contact and will manage media inquiries and other needs.
  • Website Manager – Terri Long – Terri will serve as the individual responsible for posting and updating information provided through NAMA’s website.
  • NAMA Member Outreach – Jim Meyers – Jim will be responsible for communicating with NAMA members.
  • Communications Consultant – Dezenhall Resources – If the crisis team so determines it is necessary, Dezenhall Resources is available to provide outside counsel and hands-on support.
  • Legal Counsel – Skip Myers, Morris, Manning, Martin, LLP
  • Food Safety Legal Counsel – Ricardo Carvajal, Hyman, Phelps & McNamara

NAMA-Member Crisis-Escalation Procedure

Should a crisis-catalyst emerge, there are circumstances when NAMA should gain Board input and approval prior to making a statement or taking any action. Obvious situations when this should occur include when a crisis catalyst:

  • Has the potential to result in significant, wide-spread impact
  • Involves an issue where NAMA policy is not well-defined
  • May involve the allocation of significant financial resources
  • Where issues regarding legal liability and regulatory responsibility are severe

Members of NAMA’s Crisis-Escalation Team include the members of the NAMA Executive Committee. They must agree to make themselves available at all times, and they must have the authority to authorize NAMA to take actions necessary to address a crisis situation.

Crisis Management Resources

Document inquiries and conversations with outside parties.

  1. Contact Log Sheet – After the NAMA Crisis Team has mobilized to address a catalyst, each team member should document each outside inquiry on to a Contact Log Sheet.  Not only will this assure that inquiries are efficiently managed, it enables the recreation of a detailed chronology of NAMA’s actions, if necessary.
  2. Media Interview Prep Sheet – Prepare before an important media interview. We recommend that NAMA’s communications leader complete the Media Interview Prep Sheet prior to the spokesperson speaking with a reporter.
  3. Crisis Planning Grid – The Crisis Planning Grid enables someone leading a group discussion to capture key comments and focus the team toward a set of strategies.
  4. NAMA Member Critical-Event Alert – The Member Critical-Event Alert template provides consistency in communicating to members about a crisis situation. It is also essential that members know that a communications alert is urgent information.
  5. Audience Communications Matrix – The audience communications matrix provides a quick, easy-to-follow planning guide for mapping out communications strategies and tactics.

Food Influentials Email List

In a crisis, the media, consumers, government officials and other decision-makers will turn to food influentials for information, and these influentials may develop and disseminate their own materials. NAMA will use these influentials as a conduit of crisis-urgent information. An email list of groups and individuals that are food influentials including:

  • Ambassadors (spokespersons) of the American Dietetic Association
  • National reporters and food writers
  • Consumer affairs directors of your members’ customers and retailers
  • Leading mainstream consumer groups
  • Targeted Members of Congress
  • Press offices of USDA, FDA, etc.
  • Allied national and state trade associations

Potential Crisis Scenarios

Identifying the most likely, high-impact crisis scenarios facing NAMA is a useful way to accelerate the association’s preparations and to detail a viable set of responses. This plan addresses two scenarios, some of which lend themselves more to advance planning and activity, while others are best prepared for reactively.

The objectives of this scenario-planning process are to:

  • Heighten awareness within NAMA and its membership of the most likely high-impact crisis scenarios facing the industry.
  • To identify in advance the decisions, strategies, and resources that NAMA will need to address to effectively manage the situation; this should enable NAMA to prepare now for what it will need should a crisis hit.
  • Provide a viable set of preemptive actions, where appropriate, and reactive actions that NAMA can consider (and perhaps implement) should one of these scenarios unfold.

In the event of the identification of a crisis catalyst, NAMA will develop and implement crisis management activities through following this fundamental approach:

  • Verify and Monitor – The first series of decisions and actions establish the veracity of any report of a crisis catalyst, assemble the crisis team and initiate procedures to monitor the catalyst’s further development.
  • Determine NAMA’s Role – The second set of decisions and actions help NAMA determine what its role, if any, is in responding to the crisis.
  • Determine Strategies and Audiences – The third step involves identifying priority audiences for communications and recommends potential strategies for addressing the situation.
  • Develop Messages and Materials – This section recommends basic message “themes” (detailed recommendations are not practical given we don’t know the specific circumstances) and indicates which communications tools need to be developed.
  • Develop and Implement Communications and Actions This section is the most extensive and provides a blue-print for communications and other actions to manage the crisis in its early stages.
    • Further Action, Feedback and Closure – This final section provides a list of recommended decisions and actions to determine what further actions are needed, how to assess feedback and when to and how to gain closure, if possible.

    These scenario-response plans are not intended to be exhaustively detailed, dictatorial action plans.  Their value is to provide well-considered direction  —  guideposts that NAMA should look for, while it reconsiders each step.  No crisis actually happens in a manner that is planned for, and very quickly new dynamics emerge. 

    The following scenarios have been identified as the most pressing to develop response plans:

    1. Microbial Contamination – An outbreak of bacterial food-borne disease is traced back to a NAMA member’s facility.
    2. Food Supply Contamination by Biopharmaceuticals – A test reveals the presence of a crop-derived genetically-modified pharmaceutical ingredient not approved for food in a milled food product.

    SCENARIO: An outbreak of bacterial food-borne disease is 
    reportedly traced back to a NAMA member’s facility.

    CRISIS RESPONSE

    Potential Threats

    • Serious illness or death by affected consumers.
    • Public panic and illness wrongly attributed to milled products.
    • Government requires recall far wider than necessary.
    • Politicians use the event to press for tougher regulations.
    • Financial losses resulting from government-ordered destruction of grain and milled products or declared quarantine on facilities.
    • Retailers and food processors demand guarantees and documented assurances that milled products are free of contamination.
    • Rising costs of business caused by introduction of new tests or procedures designed to assure purity of milled products

    NAMA’s Role

    • Maintain consumer confidence in the overall safety of milled products.
      • Assist affected member with government relations/regulatory needs.
      • Ensure that governmental actions do not unnecessarily and adversely affect the industry at large.
      • Minimize damage to milling industry’s reputation.
    • Note that NAMA should not comment on the specifics of the incident, this is better left to the affected member or members. Rather NAMA should be a source of general information, speaking on behalf of the entire industry where appropriate.

    If the food-borne outbreak is limited, NAMA’s role will likely be confined with offering regulatory guidance.  If it is widespread or results in serious illness or death, NAMA’s role will likely be larger and more public.  NAMA does not speak for the company.

    SCENARIO: A test reveals the presence of a crop-based genetically-modified pharmaceutical ingredient (e.g., a vaccine) not approved for food in a finished product, such as flour or ready-to-eat food, and a NAMA member facility is implicated.

    CRISIS RESPONSE

    POTENTIAL THREATS:

    • Unknown but potentially harmful public-safety impacts.
    • Product recalls of all products potentially affected.
    • International embargoes on US products.
    • Significant liability issues.
    • Extensive governmental investigations, hearings, inquiries, etc.
    • Consumer and media confusion/hysteria over safety of milled products, i.e., the public believes it is the milled food, not the biopharma product, that is “biotech” and, thus, the threat.

    NAMA’s Role:

    • Serve as a/the major voice of the milling industry to maintain consumer confidence.
    • Use a negative incident as an “opportunity” to drive regulatory policy in the appropriate direction.
    • Prevent an overreaction among international trade partners, or their using an adverse event as a non-tariff trade barrier.
    • Advise affected member (members) on public policy matters and act as a Washington liaison.
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