Guides for product recall assistance

                                                                                                                                                                                       

Recall of products from the market may turn into a corporate tragedy if manufacturers and other businesses involved are not duly prepared and has a cost-effective process to handle it.

Several guides have been developed by both national safety authorities and standards bodies in different countries. In the U.S., the Consumer Product Safety Commission (CPSC) published recently updated guidance now called “Product Safety Planning, Reporting, & Recall Handbook” . It includes a new section titled “Plan Ahead: Compliance Programs & Designating Responsibility for Product Safety Issues”, and also an appendix on how to develop a compliance program.

In the UK, the newly formed UK Office for Product Safety & Standards has prepared a guide entitled “Product recall and other corrective actions – Code of practice” (PAS 7100:2022) published by the British Standards Institution (BSI). It is to be read in conjunction with PAS 7050:2022, which supports businesses and regulators in “complying with their relevant legal duties relating to placing safe products on the market.”
The PAS 7100 incorporates changes regarding UK’s exit from the EU, aligns with the revised version of PAS 7050, and adds new sections for online marketplaces and for repair and refurbishment.

Also, the EU Commission and the governments of Canada and Australia have developed various recall guides, especially for consumer products.

In 2013, ISO issued the standard ISO 10393, providing guidelines for consumer product recalls. All aspects of a comprehensive recall program are contained in this ISO standard.

However, being guides and mere recommendations neither of these documents constitute legal requirements, and therefore, compliance may not provide any legal immunity.

All the guides are quite similar on how to develop a compliance program and emphasize that product marking and traceability procedures are significant elements of the product’s design, manufacture, and distribution processes. Especially safety-critical components should be marked or coded so that anyone, including customers, can easily identify a recalled product and remove the component to be returned or repaired.

In the event of a recall, this traceability will allow a manufacturer of the finished product or component part to narrow the affected population and allow customers to more easily identify whether their product is subject to the recall. A customer might even be able to return the affected part and replace it with a new one. In that case, everyone benefits, from the manufacturer to the retailer to the consumer.

More information about this may be seen here.

(Article is based on an InCompliance article edited by T.Sollie)