Product Recall Code Launched for Consumer Products

The UK government’s new Office for Product Safety and Standards has launched the first code of Practice (PAS 7100) for product safety related recalls.

“Code of practice on consumer product safety related recalls and other corrective actions”

This new code of practice  is targeted at two audiences:

  • Businesses producing, importing and distributing non-food consumer products
  • Enforcement authorities

The document is split into two parts accordingly.  It states that “For business – the Code will help manufacturers, importers and distributors prepare fully to deal with any product safety issue that might arise with their products.” Whilst “For local authorities – the Code sets out the guidance and advice they should make available to enable businesses to meet their legal responsibilities and act in the public interest.”

Product Recall Plan and Incident Response

Part I provides guidance for businesses on: preparing for a product recall, monitoring safety of products, investigating potential product safety issues, procedures for dealing with a product safety issue and reviewing corrective action procedures.  In short, it provides advice on preparation of a Product Safety Incident Plan (PSIP) or product recall plan.  This includes key elements: Traceability, Monitoring, Legal notification, Risk assessment, Decision making, Communications, Training, Testing and Review.  There is useful content on the incident management process from learning of a potential product safety issue, through decision making, action and review.

The Authorities

Part II, the regulator section, describes how the authorities may be able to assist companies outside an incident in an advisory role.  It also explains how authorities can assist businesses during a product safety incident in addition to their enforcement role.  This support sounds positive and companies should understand how best to engage with their authorities before and during a product safety incident.

RQA’s View

  1. This is a useful guidance document containing many elements that will help consumer product manufacturers to prepare their product recall plan. It will also aid them in understanding their responsibilities and the actions required by enforcement authorities in response to an actual incident.
  2. Time will tell if the authorities’ budgets and human resource allocation will meet the aspiration of support and advice to businesses as described in the Code.
  3. The Annexes include details of the RAPEX risk assessment methodology; this is the EU method as defined in EU legislation (Commission Decision of 16 December 2009). It also includes the Nomograph method applied in Australia, New Zealand and Slovenia.  The Nomograph method is a simpler method, and it is a little surprising to see its inclusion in the code of practice as it is the RAPEX method that is referenced in the EU and used by EU authorities.  It is for this reason that RQA always apply the RAPEX method when assisting clients who have potential safety issues with products in Europe.
  4. The Code specifically states “Producers, importers and distributors operating in the UK should each have a PSIP in place.” This is very good advice as without a plan, businesses will struggle when faced with the complexities of a product recall.
  5. Disappointing that this “Publicly Available Specification” costs £90. Whilst that is not a financial problem for most businesses, it will restrict the flow of this document through open transmission over the internet and limit access from the general public, academia etc.  For example, PAS 96:2017 on “Defending Food and Drink…” is a free download from the BSI website.
  6. Development of this PAS was sponsored by the Department for Business, Energy and Industrial Strategy (BEIS) following a recommendation of the Working Group on Product Recalls and Safety (WGPRS).
  7. This PAS is not to be regarded as a British Standard.

RQA can offer you a gap assessment to this new code, for further details on this click here. For more information on our product recall, risk assessment or other related services please contact us on contact@rqa-group.com or call us on +44 (0)118 935 7242

To visit the BSI website and purchase the Code click here