Tuesday, April 17, 2007

RECALL PLANs

Product Recall Procedures
. Identify who, what, when, where, and how for recalls
. Identify additional relevant points of contact
http://www.cpsc.gov/businfo/8002.html


1. What and Where to Report
The following information should be transmitted / report:
· Description of the product.
· Name and address of the company, and whether it is a manufacturer, distributor, importer or retailer.
· Nature and extent of the possible product defect or unreasonable risk of serious injury or death.
· Nature and extent of injury or possible injury associated with the product.
· Name, address and telephone number of the person informing the Commission.
· A timetable for providing information not immediately available.

2. When To Report
A company must report within 24 hours of obtaining reportable information. It was to report potential substantial product hazards even while their own investigations are continuing. However, if a company is uncertain whether information is reportable, the firm may spend a reasonable time investigating the matter. That investigation should not exceed ten working days unless the firm can demonstrate that a longer time is reasonable in the circumstances.



To determine whether the product creates a substantial hazard, the staff will applies hazard priority standards to classify the severity of the problem.
The hazard priority system allows the staff to rank defective products uniformly. An example would be a Class A hazard rating is reserved for product defects that present a strong likelihood of death or grievous injury or illness to the consumer.If it was said the product creates a substantial product hazard; the hazard priority system also provides a guide for selecting the level and intensity of corrective action.



Class A Hazard
Exists when a risk of death or serious injury or illness is likely to occur
Class A hazards warrant / requires the highest level of attention. They call for a company to take immediate, comprehensive, and imaginative corrective action measures to identify and notify consumers, retailers and distributors having the defective product and to remedy the defect through repair or replacement of the product, refunds, or other measures.

Class B Hazard
Exists when a risk of death or serious injury or illness is not likely to occur, but is possible

Class C Hazard
Exists when a risk of serious injury or illness is not likely to occur, but is possible
No matter if a product defect is classified as a Class A, B or C priority hazard, the common element is that each of these defects creates a substantial product hazard that requires corrective action to reduce that risk of injury.

http://www.cpsc.gov/businfo/8002.html



Putting Together a Corrective Action Plan

A. Preparing For A Product Recall
It is unlikely that any two recall programs will ever be identical.
Therefore, companies should be prepared to address issues that invariably arise. For example:
-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 many are there?
-Did the product fail to comply with government safety regulations? How?
-Was the government or the appropriate regulatory body informed about the defect or lack of compliance?
-Has the company discontinued production and shipments of these products to distributors?
-Has the company notified retailers to stop selling the product and asked them to help identify consumers who own the product?
--Has a press release been prepared announcing the recall? What other forms of public notice are needed?
-Has a toll-free telephone service been set up that will be able to handle the number of calls expected after the recall is announced?


B. Elements of a Recall
A company that undertakes a recall should develop a comprehensive plan that reaches throughout the entire distribution chain to consumers who have the product. The company must design each communication to motivate people to respond to the recall and take the action requested by the company.
A plan must include the company's agreement that the Commission may publicize the terms of the plan to the extent necessary to inform the public of the nature of the alleged substantial product hazard and the actions being undertaken to correct that hazard.
The objectives of a recall are:
-To locate all defective products as quickly as possible;
-To remove defective products from the distribution chain and from the possession of consumers; and
-To communicate accurate and understandable information in a timely manner to the public about the product defect, the hazard, and the corrective action. Companies should design all informational material to motivate retailers and media to get the word out and consumers to act on the recall.

In determining what forms of notice to use, the paramount consideration should be the level of hazard that the recalled product presents.
Class A hazards warrant the highest level of company and Commission attention. Other considerations include where and how the product was marketed, its user population, the estimated useful life of the product, and how the product is most likely to be maintained and repaired.
A company conducting a recall must take particular care to coordinate the notice portion of the recall so that all participating parties, including retailers, have sufficient advance notice so that they can carry out the actions agreed upon.



Following are some specific suggestions for communicating recall information:
A. News Releases
The Office of Information and Public Affairs sends the news releases to national wire services, major metropolitan daily newspapers, television and radio networks, and periodicals on the agency's news contact mailing list. News releases from the Commission receive wide media attention and generate a good response rate from consumers.
[Each recall news release should use the word "recall" in the heading]
Recall news releases must include the following:
· The name and location of the recalling firm
· The name of the product
· The number of products involved
· A description of the hazard
· The number of deaths, injuries, and incidents involving the product
· Detailed description of the product, including model numbers, colors, sizes, and labeling
· A line drawing or photograph of the product
· Major retailers and where and when the product was sold and retail cost
· Complete instructions for consumers on how to participate in the recall

B. Video News Releases
A VNR increases the chances that television news media will air information about a recall because it effectively provides news of the recall to television news producers in the form that they need.


C. Posters
Posters are an effective means of providing continuing notice of recalls to consumers at points of purchase or other locations that they visit. Guidelines for posters and counter cards:
· Keep them BRIEF and eye-catching; in general, a poster requires far fewer words than a news release.
· Describe the hazard and tell consumers what to do.
· The firm’s toll-free telephone number should be in large size type at the bottom
· of the poster.
The company should also:
Advise retailers or other firms to place the posters in several conspicuous locations in their stores or offices where customers will see them, e.g., the area where the product was originally displayed for sale, store entrances, waiting rooms in pediatric clinics, service counters at repair shops.



D. Other Forms of Notice
Like news releases and posters, letters, advertisements, bulletins, newsletters, and other communications about a recall need to provide sufficient information and motivation for the reader or listener to identify the product and to take the action you are requesting. They should be written in language targeted to the intended audience.
The words "Important Safety Notice" or "Safety Recall" should appear at the top of each notice and cover letter and should also be on the lower left corner of any mailing envelope.

Conclusion
Consumers no longer view product recalls negatively. Millions of products have been recalled over the years. In today world, consumers believe they enjoy a safer, better product as a result of a recall conducted responsibly by company. It is important a company conducts a timely, reasonable recall of a product because it can have a strong influence on consumers' attitude about the firm. Successful product recalls in the past have rewarded companies with continuing consumer support and demand for the firms' products. Some examples are NESTLE and KIT KAT which occurs some months ago.

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