How A Company Undertakes A Product Safety Recall
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This file provides information on initiating a product recall when the CPSC staff determines that the hazard associated with a product warrants such action.
OBJECTIVES OF A RECALL
Once the CPSC staff determines that a product is in violation of a Commission statute or regulation, it will notify you in a Letter of Advice (LOA) that corrective action to address the violation is warranted. The LOA generally will also include specific corrective actions the CPSC staff believes are appropriate to address the violation. The LOA will request you to submit a voluntary corrective action plan detailing steps you intend to take to correct the violation. This corrective action plan, after being reviewed by the CPSC staff for adequacy, forms the basis for any action you plan to take to resolve the problem.
In some instances, because of the nature of the hazard and the likelihood of serious injury associated with the noncomplying product, CPSC will request that the product be recalled from the marketplace.
The objectives of a recall are:
1. To locate as quickly as possible all noncomplying products;
2. To remove noncomplying products from the distribution chain and to retrieve them from the possession of consumers; and
3. To communicate accurate and understandable information to the public about the violation, the hazard to consumers, and the corrective actions planned to address the hazard.
METHODS OF RECALL NOTIFICATION
Each method of notifying the public of a product recall used by a company must be agreed upon in advance by the Commission staff.
It is, therefore, very important for you to provide advance copies in draft form to the CPSC Regional Office staff prior to sending notifications out to customers or consumers.
Following is a discussion of some specific methods for communicating recall messages to customers and consumers: Notices To Customers (Distributors and Retailers)
One common form of notifying customers (including retailers and distributors) that a recall is being undertaken is to provide direct notification to the customer in the form of a letter or similar communication. The following points should be taken into consideration when developing notification letters:
* Letters or other forms of communication must be specific and concise.
* A heading such as "SAFETY RECALL NOTICE" or "IMPORTANT SAFETY NOTICE" must appear in the lower left hand corner of the envelope and at the beginning of each letter.
* The letter or communication must state that the recall is for safety reasons.
* The nature of the product hazard, as well as the recommended action for the consumer, distributor, or retailer, must be described in the letter.
* The letter must be individualized for the target audience (one letter for consumers, a different letter for distributors, yet another for retailers).
Point of Purchase Posters
A common form of consumer notification of a recall is the display of point of purchase posters at the retail outlet which sold the recalled product to the public. Such posters are generally prepared by the recalling company and sent to the retail store along with instructions for displaying the poster in a prominent location in the store for a specific period of time. While typically CPSC will request that the posters be displayed for 120 days, a different time period may be specified, depending on the circumstances.
* Posters and counter cards must be printed in colors that contrast with the background of the poster or counter card.
* Posters and counter cards must be displayed so that they are readily visible and not blocked from consumers' view by other signs or products being sold. The message must also be easily understandable for consumers.
* Posters and counter cards must be displayed in several conspicuous locations throughout the store. Locations include: on the shelf where the product was routinely sold, at checkout counters and customer service desks, and at the entrance and exit to the store.
* Posters may fit standard store display holders. Ideally, posters should be no less than 11 by 17 inches to be clearly visible to shoppers.
* Counter cards may also fit standard display holders. Ideally, cards should be no less than 8 1/2 by 11 inches.
Unless you can identify all purchasers of a product being recalled and notify them directly, CPSC will seek to issue a press release jointly with your firm. Such releases are made available to the national wire services (AP and UPI), major metropolitan daily newspapers, television and radio networks, and periodicals on the agency's press contact mailing list.
If CPSC requests that a press release be issued, the press release will be prepared by the CPSC Regional Office in conjunction with the Commission's Office of Information and Public Affairs. A draft release is sent to you for verification of content prior to being finalized and issued by the Commission.
Usually, the release from the Commission generates the widest media attention and consumer response. In some cases, companies involved in a product recall may prefer to issue their own (unilateral) press release. However, this tends to complicate matters since the CPSC is also releasing the news release and it could create confusion among the public.
Each product recall press release agreed to or unilaterally issued must contain the following information:
* The name of the product, the manufacturer, and the specific product hazard;
* The suggested retail price of the product;
* A description of the product and its intended use;
* The model and serial number of the product, and where consumers will find the data on the product;
* Dates and time periods of product availability, distribution, and sales to assist consumers determining if they bought the product;
* Guidelines for discontinuing use of the product, if applicable;
* Directions as to how consumers may obtain refund, replacement, or repair of the product;
* Major national stores or chains selling the product;
* A description of the defect and the date the Commission was first notified of its existence;
* A name and "800" telephone number for consumers to use if they wish to contact the company with questions about the recall.
A glossy, black-and-white photograph or line drawing from the company showing the product and the violative condition is also recommended. Duplicating the photograph and/or line drawing and providing it to the media with the release usually eliminates any confusion and often resolves their questions.
Consumers no longer view product recalls in a negative light. Many thousands of products have been recalled over the years. Today, consumers believe they enjoy a safer, better product as a result of a recall. How well a company conducts a timely, reasonable recall of a product it produced can have a strong influence on the consumer's attitude about the firm. Successful product recalls in the past have often rewarded companies with continuing consumer support and demand for the firms' products.
Excerpted from the REGULATED PRODUCTS HANDBOOK
U.S. Consumer Product Safety Commission, Office of Compliance
February 1994 - 2nd Edition*
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