If you have a product recall team in place to prevent and plan responses to recalls, then in addition to their ongoing, evolutionary actions, there are several steps already required for children’s products and their packaging that should be considered.
If at all feasible, procedures can be created that will permit tracking of all products sold, either by lot number or production period.
The Consumer Product Safety Improvement Act (CPSIA) requires all children’s products and their packaging to contain permanent, distinguishing tracking labels that will:
Manufacturers should also consider using product registration cards for consumers to fill out and return, identifying information such as model number, style number and special features of the product that was purchased.
Registration cards, coupled with an easily retrievable customer database, can be an effective tool for identifying owners of recalled products. In fact, their use is mandated for certain ones.
The CPSIA mandated that the Consumer Product Safety Commission (CPSC) enact a final consumer product safety rule requiring each manufacturer of a durable infant or toddler product to provide customers with a postage-paid consumer registration form with each product. In addition, companies are required to maintain a record of customer contact information for each registered product for at least six years that can be used to contact registrants in the event of a product recall or safety alert.
The use of accurate records and product labeling will not only enable a manufacturer to isolate defective products and potentially limit the scope of a recall, but will also facilitate rapid and widespread notice to customers, distributors and end users when a recall is needed.
To avoid and minimize potential litigation or governmental exposure, the best antidote is prompt, clear and concise notice to all persons affected by the recall, including direct notice to end users or consumers whenever possible.
For example, Williams-Sonoma Inc. was commended by the CPSC in 2001 for using its own electronic credit card records, in conjunction with bank credit card companies, to identify purchasers of recalled portable gas grills. By notifying purchasers individually and offering a full refund and $50 gift certificate, the company was able to make its recall successful, with more than 99% of the grills returned.
Anticipating how best to accomplish this goal and, when possible, establishing procedures to streamline the notification process before it is needed is a worthy project for the product recall team.
It may also be a good idea to explore product recall insurance to cover out-of-pocket costs associated with a recall.
Armed with the advance planning and continuing dialogue, the product recall team can rapidly respond when a potential recall is identified.
When the facts and circumstances dictate—and permit—the team can move on to conceiving and developing a definitive fix for the perceived problem, one that cures an identified concern without creating new dangers or concerns.
A well-prepared and experienced team thoroughly understands the product and the uncertainties surrounding it and is able to find the cause and engineer a solution quickly.
If negotiation with the CPSC or another governmental agency is required before instituting a public recall, the product recall team’s knowledge, competence and past involvement with product review can prove invaluable.
To avoid making decisions that are neither timely nor correct, it is imperative that people with the requisite skill and product and marketing savvy are named to the product recall team and actively participate in its deliberations and testing.
If the manufacturer does not have adequate or available internal resources, it may consider having its legal counsel retain outside expertise.
The goal is to do it right the first time and thereby obviate the need for any further recalls of the same product—an event that is embarrassing, expensive and destructive to the brand. For this reason, a product recall is often seen as a process, one that is approached methodically and thoughtfully, with disciplined brainstorming, vetting, testing and double-checking.
Once a recall is initiated, the manufacturer’s liability and product recall insurance carriers should be notified and kept abreast of major developments.
The product recall team can also assist in this effort because it is equipped to respond to the carrier’s inquiries carefully and accurately.
Excerpted from David G. Klaber and Jared S. Hawk, “Be Prepared: What every company should do to weather a product recall,” Quality Progress, May 2010, pages 16-21.