A product recall can be an ordeal. Businesses have to move fast or risk real damage, either in fees or litigation, or to their reputations and relationships with customers. And they are commonplace across almost every consumer product industry. Some, like Peloton’s recent recall of its Tread+ treadmill, even make the nightly news. But with the right groundwork in place and an honest communication strategy, a recall can be managed with minimum disruption to a business or its image.

Recalls stem from design or manufacturing defects that could create a substantial or unreasonable risk of injury or death, or if a product fails to comply with mandatory regulatory requirements or standards, or bans.

Of course, the best way to deal with a recall is to avoid it entirely. Suppliers, manufacturers and importers can take steps in the design, development and production of their product to eliminate the potential for design and manufacturing defects—which are what give rise to injuries and ultimately to recalls. Having the right product expertise, failure mode and effects analysis, testing, production oversight and quality management systems in place make for safer products.

“That is the essence of product safety. Some level of oversight that you can trust,” says Rick Brenner, MAS+, president and CEO of Product Safety Advisors. “It makes much more sense to avoid a defect in the first place than have to deal with one afterwards.”

Brenner says, “A recall is triggered by some kind of incident. ‘My client just told me that such and such blew up.’ That’s all. That’s not the time to figure out what to do. You need to know what to do, right then and there.”

Recall readiness is understanding how to react when an incident happens: who to contact, how quickly to respond and what information is needed on-hand.

“The first thing to do, to prepare in-advance for any potential recall, is to create a team on staff to lead your response,” Brenner says. “Assign a team lead who has the authority to make decisions regarding the recall. Include your director of operations, head of marketing, and a pre-vetted product safety attorney. It’s critical to get advice and a knowledgeable attorney is worth their weight in gold in a recall. Everyone on the team has to be trained and understand their role.”

Section 15B of the Consumer Product Safety Act (CPSA) mandates that businesses have 24 hours to report a recall to the Consumer Product Safety Commission (CPSC) upon obtaining information that “reasonably supports the conclusion” that a product poses a hazard or fails a standard. There is a fair amount of latitude and time within the CPSA for a company to investigate claims of a defect and decide whether or not they will report to the CPSC, however.

A company that has prepared for potential recalls can take advantage of the CPSC’s FAST TRACK system, which requires a full report within 20 days. If a company reports and implements a corrective action that CSPC staff believes will be effective within 20 working days after filing an initial report, the CPSC will generally refrain from making a preliminary determination that the product contains a defect that creates a substantial product hazard. To be able to complete a report within 20 days, companies need to be able to gather and summarize all the data needed—sales records, purchase records, etc.

Central to any effective recall response is having the right information quickly available, which means developing systems that put the right information in the right hands in a timely fashion. This can extend all the way to how products are tracked as they are imported. Brenner says, “When you make a report to the commission, the first question they’re going to ask is ‘how big of a problem is it?’ And if you’ve never done anything to distinguish between lot one and lot 4,000, all they can say is recall them all.”

Reputational injury and the loss of consumer trust following a product recall, particularly a high profile one, is a legitimate concern for businesses. But working with the CPSC and communicating the issue and the company’s response clearly to customers and stakeholders goes a long way, according to trust experts, on restoring confidence in a brand. 

Sandra Sucher, Harvard Business School professor and author of The Power of Trust: How Companies Build It, Lose It, Regain It, says, “Lost trust can be recovered. It’s a definite process unto itself. I think for people who are in the business of creating and delivering products that meet other people’s requests, being able to recover from moments that didn’t go exactly right is a big deal. It’s not easy, but lost trust can be recovered.”

Rebuilding lost trust is a three-step process, Sucher says. Her first is simply to acknowledge the harm and apologize for it. The second is to provide an explanation of what went wrong. People want to know how it happened. Sucher says, “The explanation is really important because people are very curious. It can’t be defensive; it has to be a straight up explanation of what went wrong.”

The last step is the offer of repair. In the promotional products industry, this can be as simple as replacing the defective product. Sucher says, “This is where you tell people, ‘Here’s what we’re going to try to do to fix that situation so that it won’t happen again.’ That’s the kind of thing people are looking for. They want to know that you acknowledge the harm and that you’ve apologized. It lets people know that you live in the same world that they do. Something bad happened and you’re taking responsibility for it.”   


Khattak is the news editor at PPAI.