Get answers to the following questions: When should a product be recalled? What is an example of a product recall? What products have been recalled recently?
A product recall is a request for consumers to return hazardous products to the manufacturer. According to the Consumer Product Safety Commission (CPSC), a product may need to be recalled if it has a defect that causes a substantial risk of injury. Though manufacturers are highly encouraged to conduct product recalls voluntarily, in some cases, the CPSC or other national authority can mandate a product recall.
Below are three examples of major product recalls that have taken place throughout the years:
Automotive Industry: Toyota Accelerators – Faulty pedals caused unintended acceleration, leading to Toyota recalling around 8 million of their vehicles in 2009-2010.
Pharmaceutical Industry: Merck Vioxx – The Non-Steroidal Anti-Inflammatory Drug (NSAID) was found to increase the risk of heart attacks, resulting in Merck recalling the drug 5 years after it was released to consumers.
Food Industry: Peanut Corporation of America – A salmonella outbreak linked to two of the company’s processing plants led to a widespread product recall issued by the Food and Drug Administration (FDA).
Products that have been recalled recently (in 2022) include:
129,000 Bestar Wall Beds recalled due to serious impact and crush hazards
89,000 Sakar Dimensions Bluetooth Speaker Helmets recalled due to risk of head injury
19,000 Sirrus Bicycles with alloy cranks recalled due to fall and injury hazards
32,000 Honda Talon Recreational Off-Highway Vehicles (ROVs) recalled due to crash and injury hazards
1,693,000 Fitbit Ionic smartwatches recalled due to burn hazard
Even before a product recall procedure begins, manufacturers should form a cross-functional product recall team and create a comprehensive product recall plan, if they haven’t already. This is because as soon as they receive potentially reportable information, manufacturers will need to start the product recall procedure and do the following steps:
According to the Consumer Product Safety Act (CPSA), reportable information includes any information that indicates a product’s failure to comply with a consumer product safety rule, standard, or regulation; or that it contains a defect which could cause a substantial hazard or risk of injury. Upon receiving potentially reportable information, manufacturers have 10 days to conduct an investigation and determine if the information is reportable. A product traceability system in place can significantly accelerate this process by providing a detailed audit trail of all materials and production steps.
If manufacturers are certain that information is reportable, they should report it to the CPSC within 24 hours of receipt or identification. This initial report should contain the product’s description; details of the manufacturer; nature and extent of the defect, non-compliance, or risk; nature and extent of injury or risk of injury; as well as the name and address of the reporter. An additional full report may also be required by the CPSC in certain cases.
Reports can be sent to the CPSC through their website or email. Digital reports should be confirmed in writing within 48 hours of their submission to the CPSC.
Upon filing the initial report, manufacturers can choose to immediately (within 20 days) implement a recall through the CPSC’s Fast Track Recall Program. The main benefit of participating in the program is that the CPSC will not make a preliminary hazard determination. To join the Fast Track Recall Program, manufacturers need to:
submit the initial report through the CPSC website;
stop the sale and distribution of the defective product; and
be ready to implement a corrective action plan.
The product recall is only one part of the corrective action plan and the CPSC may have other suggestions which manufacturers in the Fast Track Recall Program will need to follow.
Another option after submitting the initial report is to simply wait for the CPSC to evaluate the report and cooperate with them when they ask for information and further documentation. In some cases, the CPSC may decide that no corrective action, such as a recall, is needed.
Once the need for a product recall has been identified, it’s important for manufacturers to work closely with the CPSC, especially when communicating to the public about the recall. The CPSC must first approve product recall messaging before it is released, regardless of platform or media format. Aside from the general public and consumers of the product, manufacturers must also notify their distributors, retailers, and suppliers (e.g., when an issue is traced to the supplier of a component or raw material).
After implementing a product recall, manufacturers need to submit Monthly Progress Reports (MPRs) through the CPSC Business Portal. Access to this system can be given by either the compliance officer assigned to the recall or another user with access to the system. Manufacturers must submit MPRs until the CPSC tells them not to do so.
Integrating improvement in practice
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Develop a culture of safety and quality – Encourage employees to speak up when they see something wrong and set up a system for measuring and maintaining quality. Make safety a daily practice for employees at all levels by requiring the use of mobile-friendly checklists.
Perform regular product inspections – Inspect the quality and safety of products before they reach consumers and be honest about the inspection results. Accomplish the necessary corrective actions to make your products up to standard and ready for market release.
Enforce standard operating procedures – Review and update Standard Operating Procedures (SOPs) before implementing them across the entire organization. Ensure that following SOPs is both easy and convenient for employees so that they’re more likely to stick with the established protocol.
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Based on the Recall Execution Plan in the Product Safety Planning, Reporting, and Recall Handbook and the Recall Checklist from the CPSC, this template is used by manufacturers to adequately prepare for product recalls. The template includes the requirements for a product recall plan and a recall communications plan as well.
Based on the 10 Steps to an Effective Compliance Program provided in the CPSC Product Safety Planning, Reporting, and Recall Handbook, this checklist can help manufacturers effectively prevent product recalls from ever occurring. The checklist contains items such as:
Create a system for employee reporting
Establish a central database to track information
Prioritize senior management responsibility for compliance
