After The Decision To Recall

You have received a number of complaints; your product recall team has worked hard and intensively to investigate. You know where the affected product is (or at least most of it) and you and your recall team have made the decision to recall. But what happens next?

RQA has looked at hundreds of recall plans over the past 20 years. Some good, some very poor, but only a small proportion would be considered first class. The issue we see in so many cases is that the plan does not include much guidance on what to do after recall action has been decided. It is almost as though the difficult bit has been done; the investigation, the testing, the decision making, and everyone involved wants to take a breath. Unfortunately, reality is not like that at all. Once you “press the button” for recall, the work really starts.

Let’s work through a possible scenario, where everything below is based on real events:

We’re Recalling – Now What?

The recall team have decided to recall products. In this simple scenario, the affected product is only sold in one country. As the recall team leader, you are tasked with making sure it happens. You take a look at your recall plan, only to find there is virtually nothing in there to help you with the recall itself. There is one short section that says, “notify the authorities and your retail customers of the recall”. Sounds sensible, but who specifically do you tell? When do you tell them? You probably should already have been in discussions with the authorities and customers as it was becoming clear that the incident was serious. In fact, some countries define notification time by law from the time an issue is discovered. Do you know what the different legal requirements are for the countries where all your products are sold?

Notify Who and How?

How do you notify the authorities? Do you phone them up or email them? The authorities may have an official notification form. Do you know where to find that form?

We have seen several cases where the weblink to the authority’s notification form in recall plans is out of date or doesn’t work!

 

The good news is that as per the recall plan, the Comms team has been working on the recall communications since the issue first arose. They have identified stakeholders and developed the recall notices and briefed the social media team on how to engage and reply to specific posts about the recall. The comms team have even set up a page on your web site with more details about the recall with batch codes and images of the product. This can go live as soon as the recall team advise. There will be lots more to do, but you are well placed, at least initially, to effectively inform your consumer and manage the message.

Prepare draft recall notice templates in advance. Its easier to adapt a draft than start from a blank page.

How Do We Stop the Products Being Sold?

One of the biggest challenges in a product recall (again rarely mentioned in recall plans) is how do you ensure your products are removed from stores and consumers. Many recall plans will say “Ensure product is removed from retailers / consumers”. It rarely explains how this is done. Of course, the reality will depend on the types of outlets selling your product. If 100% are in the largest retailers, then the process should be efficient. Those major retailers will be able to quickly remove the product from shelves and block bar codes to prevent further sales. Of course, even if you can narrow the issue down to a specific batch code, it is likely that the retailer will remove all of the product from the shelf and not just the batch affected.

Getting the Message to the Consumer

Major retailers can look at loyalty cards and contact consumers who have bought the affected product directly, hugely increasing the effectiveness of the recall action. However, you will also be relying on communications to get your message to the smaller retailers and their consumers. Social media is a key tool here and can be used to spread the message using your company’s social media pages, but also by involving consumer groups and others. The use of newspaper adverts is rare these days and very ineffective. In the largest recalls or most dangerous, a senior executive from the company may do news interviews to spread the message of the recall to consumers.

Crisis communications is a huge topic on its own and so we won’t go into any further depth here, but it is worth considering how you would handle the media and your message to all stakeholders to ensure an effective recall.

We were involved in a recall where a manufacturer had informed a medium sized retailer about a contaminated product that was in several hundred stores. RQA carried out effectiveness checks and found that in one store, all the manufacturer’s range of products had been removed from sale, except the contaminated variety. The store manager had read the recall message incorrectly!

The challenge really arises when your product is sold through distributors, agents, importers and independent retailers. In that case, you don’t know where your product is being sold. For the purposes of this scenario, the affected product was only sold in one country.

We have been involved in multiple recalls where the manufacturer didn’t know that their product had been sold into other countries via wholesalers and importers. That adds a complexity that we won’t cover here.

When Do You Stop?

How far you go to remove products from sale will depend on a number of factors including the risk, danger to consumers, shelf life of the product and where it is in the supply chain. If a food product is highly dangerous but has a short shelf life of only a few days, you are under intense pressure to get the message far and wide to try to inform as many consumers as possible. By the time you are a few days beyond the shelf life, it is unlikely that there is any further danger to consumers (although you need to consider people freezing the product). However, many consumer products are likely to be around for several years and this has an impact on the scale of the recall execution. The recall may take several months or even years depending upon number of units affected and the complexity of the return or if there is a fix that can be applied.

Let’s say that your product is sold via wholesalers. It is possible that the wholesalers know who the product has been sold to, but it is unlikely that they will know this at a batch level. The challenge is getting the recall message to the wholesalers’ customers and their customers. In practice, you will probably be relying on wholesalers passing on email messages about the recall to their customers. This will probably have a pretty low success rate

We have been involved in cases where the safety risk is high and the return rate is low after recall action. This has meant that repeated recall campaigns may be required to increase the return rate.

Warehousing and Destruction

At some point in the process, you will have realised that you need to arrange extra warehouse capacity. In some cases, your existing warehouses will not have capacity, or it may not be appropriate to store the recalled products in the same warehouse as your good products. The next step is what to do with the recalled products. In some cases, there may be an opportunity to sort “good batches” from “bad batches”; enabling you to put the good product back in the supply chain. This can reduce the financial impact significantly and assist with restocking the supply chain.

RQA can carry out these inspections to significantly reduce the cost of the recall.

Is Your Recall Team Ready?

There are many other issues that will arise during an actual recall, including making decisions without full information, communication issues, logistical challenges and general stress to the recall team and the business.

Even some of the biggest recalls are forgotten quickly by consumers; assuming they ever heard about them. The ones that stick in the memory are those where the recall didn’t go according to plan. Of course, this is more likely if your company doesn’t have a comprehensive recall plan.  Give your team the skills and capability and guidance to make effective decisions and if required, execute a recall effectively. Make sure they have a plan, and make sure the plan and the team are trained and tested in a simulated exercise. It will be worth it.

If products have to be destroyed, you need to consider what is the cause of the fault. This will need to be assessed properly and a certified destruction agency may be contracted to do this. Check your recall plans, do they include contact details for extra warehousing and destruction companies? Bear in mind that if you supply products globally, certified destruction facilities may not be available in every country.

In multiple cases, RQA personnel have accompanied truck-loads of recalled products from warehouses to destruction facilities and witnessed and videoed the destruction process. This is to ensure there is no diversion or theft during transportation. It is essential that dangerous products do not make their way back into the supply chain.

For more information on our range of product recall consultancy and training services click  here or if you’d like to discuss your product recall planning needs please email us at contact@rqa-group.com or call us on +44 (0)118 935 7242.

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