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
- 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
- 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
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
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
- 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
- What is the company's estimate as to the cost of the product
- 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.
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
from the CORRECTIVE ACTION HANDBOOK
U.S. Consumer Product Safety Commission
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