Safety Product Recalls - What to Do When They Happen
You should practice your safety product recall procedures, just like you would do drills for any other emergency plan.
Products tagged "safety" are subject to the same recall standards as any other product sold to consumers. The safety recall procedure is really no different than the one for automobile, food products, and children's toys.
When a recall is issued, it's serious business. The fact that there is a worldwide process for recalls (ISO 10393:2013, Consumer product recall - Guidelines for suppliers) indicates the very high risk potential.
Beyond the risk, there are also implications for other aspects of your business. Pulling a product affects operations, production, and business continuity.
Think, for instance, of what the implications might be for a recall on fall arrest safety harnesses:
- Product failure, which could lead to injury or death
- Temporarily being unable to perform work at height, which requires a harness
- Delayed in project/contract completion times
- Product could remain in use unless all items have been recovered
- Negative perception (internal and external) regarding your recall process and actions
(Learn How to Inspect Your Fall Harness When Working Alone.)
And let's be clear. Safety products may meet all the required safety certifications and still have failures or concerns that warrant a recall.
Product recalls need to be part of your safety pre-planning. Know who the recall regulators are in your jurisdiction in order to understand what actions you are required to take. In the United States, for example, there is a joint government recall group – a one-stop shop for information.
In this article, we'll go over the procedure you need to follow when a safety product is recalled.
Preparing for Recalls
Think about everything a product goes through to get to the consumer, especially safety equipment and PPE. The best way to prevent a recall is at the design and manufacture stage. That's why a dedicated and well-vetted supply chain – the whole supply chain – for your safety products is a must.
Your company needs a safety product recall plan (SPRP) and it must be managed with comprehensive due diligence.
I would recommend making the SPRP a part of your overall emergency planning processes, within your overall safety management system.
(Find out What Should Be Included in Your Emergency Management Plan.)
You must have a tracking system in place to make sure your recall management is diligent. It literally needs to be part of someone's job. As a safety professional,
In this article, we are going to focus on the ‘User/Consumer’ end of things, what you need to do when a recall occurs and impacts your operations. You must have a tracking system in place to remain diligent in recall management. You need to ensure a timely a immediate response when a recall is issued.
Safety Product Recall Plans
So, what does an SPRP look like?
Here is a high level list for you to consider. It needs, of course, to be made specific to your organization and included in your safety education, training, and awareness. Note that this is not a numbered list. Several points will be done at or around the same time, especially at the front end.
When alerted or notified by a supplier, manufacturer, distributor, or regulator that a safety product used in your workplace has been recalled:
- Verify the information through your supply chain
- Obtain instructions from the regular or source supplier of the recalled product
- When verified, issue a stop work/use order for your company, specific to the products in question
- Take the product out of service and secure it
- Send an internal flash safety communication to all potential involved parties regarding the recall with details as to why the recall has been issued, the supplier and manufacturer, and details of the SPRP
- Clearly identify the person is charge of the recall and their contact information
- Alert stores/inventory control that a recall is underway
- Immediately determine (with stores/inventory control) where the products are in your internal supply chain, and secure any undistributed product
- Issue an order for return of the product to a central stores/inventory location – set dates, times, and process for getting the products back
- Discuss the return or disposition of the returned product with the source supplier
- Do an assessment of the impact the recall will have on operations
- Determine whether another product is available for immediate purchase and use
- Determine whether there are legal implications, insurance, or recovery that need to be followed up
- Determine whether there are media issues that need to be addressed
- When things are over, do a review of your SPRP to determine how well it worked and whether any of it needs to be modified or updated
Identifying who in the organization will be the public face and the go-to person for the recall is critical. Someone needs to be responsible. Just like an incident commander at a working fire, there needs to be a lead hand or a boss for your recall plan.
(Learn about Stop Work Authority: Why You Need It and How to Successfully Implement an SWA Plan.)
Finally, you need to be able to have in place and demonstrate a working product traceability system. You absolutely must know where a product is and has been distributed within your organization.
The risks are real. Recalls happen, even for certified, tested, and approved safety products.
Planning is the key to successfully handling a recall. Practice putting your SPRP into action, the way you would hold fire drills or run through other emergency procedures.
And because we sometimes overlook the obvious, be sure to consider your purchasing policies and practices. My personal recommendation is to only buy certified, approved, and proven brand name safety products. It won't guarantee you'll never have to deal with a recall, but it will put the odds in your favor.
Written by Henry Skjerven
Mr. Skjerven has consulted professionally for over 27 years, with extensive Canadian experience, literally from coast to coast but with a home base in Western Canada. His experience ranges from marketing, adult education, and heavy transportation (rail) to municipal public works, fleet and transportation, oil and gas construction in the tar sands, emergency response (Fire and Ambulance), Public Works, Parks and Recreation, Security, as well as human resources and software systems, including enterprise style projects.