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Companies whose products come under the jurisdiction of the CPSC should consider developing an organizational policy and plan in the event a product recall or similar action becomes necessary, whether it involves the CPSC or another government agency. This policy and related plans should focus on the early detection of product safety problems.

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Companies whose products come under the jurisdiction of the CPSC should consider developing an organizational policy and plan in the event a product recall or similar action becomes necessary, whether it involves the CPSC or another government agency. This policy and related plans should focus on the early detection of product safety problems.

A. Designating A Recall Coordinator

Designating a company official or employee to serve as a "recall coordinator" is one step firms can take in meeting their product safety and defect reporting responsibilities. Ideally, this recall coordinator would have full authority to coordinate all recalls, and have the sanction and support of the firm's chief executive officer.

The recall coordinator should have the following qualifications and responsibilities:

- Knowledge of the statutory authority and recall procedures of the Consumer Product Safety Commission;
- Ability to function as the central coordinator within the company for all information regarding quality control procedures, product safety, and consumer complaints;
- Keeping the company's chief executive officer informed about all potential product recalls and reporting requirements;
- Making recommendations, as needed, about initiating product recalls;
- The authority to involve appropriate departments and offices of the firm in implementing a product recall;
- Responsibility for serving as the company's primary liaison person with CPSC.

B. Role Of The Recall Coordinator

How can a "recall coordinator" contribute to the overall operation of the company while still being dedicated to the reporting of potential substantial product hazards?

There are diverse ways in which this can be accomplished.

At the outset, the recall coordinator should fully review the company's product line to determine how each product will perform and fail under condition of proper use and foreseeable misuse or abuse. Through research and analysis, product safety engineers can identify the safety features that could be incorporated into the product to reduce its potential for future injury.

The company should institute a product identification system if one is not now in existence. Model numbers and date-of- manufacture codes should be used on all products whether they carry the company's name or are privately labeled for other firms. In the event a product recall is necessary, the company can easily identify all affected products without undertaking a costly recall of the entire production run. Similar.y, once a particular type of product has been recalled and corrected, a new model number or other means of identification should be used on new non- defective products so distributors, retailers, and consumers can readily distinguish products subject to recall from those new, non-affected items.

Some companies have used stickers to identify products which have been checked and corrected from the recalled products until a production change could be made to incorporate a new model number or date code.

C. Preparing For A Product Recall

It is unlikely that any two recall programs will ever be identical. Therefore, companies should be prepared to address the problems that invariably arise. For instance:

- What is the defect that causes the product hazard?
- What caused the product defect to occur in the first place?
- Where are the unsafe products? How may are there?
- How did the product fail to comply with government safety regulators?
- Was the government or the ruling regulatory body informed about this lack of compliance?
- Have consumers, distributors, and retailers been told about the defective product and any resultant injuries to consumers therefrom?
- What is the company's estimate as to the cost of the product recall campaign?
- Is the company prepared to deploy manpower and fund the effort to provide replacement parts for defective products or to exchange them for new products which do not have the problem?
- Has a plan been developed to ship replacement parts or new units to distributors participating in the product recall?
- Is the company prepared to monitor the product recall and provide timely reports to the regulatory agency on progress of the recall?
- How is the company upgrading its quality control or risk analysis procedures to prevent a similar product recall in the future?

This list addresses most administrative and operational functions of a company involved in a product recall. Even if a company never incurs a product recall, it should be prepared, nonetheless, to respond to the questions listed above.

RECORD MAINTENANCE

How well a company undertakes a product recall largely depends on how effectively it gathers the information needed for the recall. This points out the obvious need for maintaining accurate records about the design, production, distribution,and marketing of each company product during its expected life. Generally speaking, the following records are essential for a company to conduct an effective product recall:

1. Production Records. Accurate data should be kept on all production runs, volume of units manufactured, lot numbers and product codes component parts, and other pertinent information which will help the company identify defective products quickly.

2. Distribution records. Data should be maintained as to the location of each product according to product line, production run, quantities shipped, dates of delivery, and quantities sold to retailers.

3. Quality control records. It is to the company's benefit to maintain records documenting the results of quality control testing and evaluation associated with each production run. If the company were confronted with a product recall, these records would help identify possible flaws in the design or production of the product. It would also aid the firm in charting the appropriate corrective action plan.

4. Complaint record. Complaints from users or others in the distribution chain can be a key source of information in that they may highlight or anticipate problems which may arise in the future. careful analysis of complaints may reveal a flaw in the product long before the product is involved in serious injuries, perhaps forcing the company into a costly recall program.

Product complaints serve as an "early warning system" and should not be ignored. In stead, they should thoroughly evaluated to determine what prompted the complaint.

The goal of any product recall is to communicate accurate and useful information to consumers, as soon as possible, who have the potentially harmful product in their possession. The recall seeks to retrieve, repairs, or replace those products already in consumer's hands as well as those in the distribution chain. Therefore, i is essential that firms have documented procedures for locating, collecting, and repairing these defective products.
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from the CORRECTIVE ACTION HANDBOOK
U.S. Consumer Product Safety Commission
October 1988

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