California League of Food Producers 11 Failure to conduct a mandatory recall as ordered is noncom- pliance prohibited under the law. Such noncompliance allows the FDA to assess civil money penalties. Perhaps the most important benefit of a voluntary recall is performing the recall on your own terms. What should I do? Take the time now, without the time constraints and panic of an actual recall to ensure you have a Recall Plan in place. Create and circulate this Recall Plan within your business so the most important parties know what to do should a recall situa- tion occur. If you do not have one, CDPH-FDB offers a sample recall plan on its website at https://www.cdph. Library/FDB/FoodSafetyProgram/FoodRecalls/SampleRe- callPlan.pdf. With a little preparation, you can minimize the cost of a food recall to your business. Nicholaus E. Johnson is an attorney at Downey Brand, LLP. He represents all sides of business and real estate transactions, assists with regulatory compliance and advises businesses on day-to-day operations. Downey Brand’s Food & Agriculture Practice provides a full spectrum of legal services to food producers, shippers, processors and retail grocers throughout California and beyond. Covering pests such as cockroaches, bed bugs, termites, ants, beetles, birds, rodents, flying insects stored product pests, and more In-house pest training available Supporting member of FSAC Entomologist on staff in all 24 branch offices GreenPro-certified technicians trained in integrated pest management (IPM) and green practices (877) 213-9903