They say ‘practice makes perfect,’ and when it comes to recalls, the phrase is spot on. Some companies may include recalls in broader crisis plans, but that often means their procedures are not as robust as necessary. Mock recalls are the single best way to determine recall readiness – but only if they are well thought out and properly executed.
Below are some of the top tips to follow for a successful mock recall.
1. Know the regulations – Whether you’re regulated by the Food Standards Agency (FSA) or the Medicines and Healthcare products Regulatory Agency (MHRA), it is important to understand the landscape. For example, it is one of the roles of the FSA to carry out controlled inspections of any meat producing facility, and they have to provide approval before the facility can operate. Equally, if you are a manufacturer of e-cigarettes, your product will need to meet the minimum standards laid down for safety and quality under the Tobacco and Related Products Directive, for which the MHRA is the competent authority.
2. Consider the complexities – Does the affected product involve lithium-ion batteries? If they will need to be transported and destroyed, you will need to consider advice from the Department of Transport which assigns different classes to what it considers ‘dangerous goods’. In addition, there are separate regulations pertaining to road transport and rail transport. Added regulations or regulatory bodies mean added complexity, so it is important to understand the entire landscape.
3. Choose a likely scenario – This isn’t the time to come up with the most outlandish worst case – or best case – scenario you can dream up. Now is when you prepare for a likely outcome. Brush up on the top causes of recalls in your industry and create a situation based on that.
4. Go through each step of the recall life cycle – Launch the drill starting with the earliest reports of a problem, whether it’s a report of contamination from a food supplier, complaints of unsafe product defects from consumers, or another trigger, the team needs to understand what to do from the very beginning – including the decision of whether to initiate a recall. Then, continue through each step of the recall life cycle. This includes identifying those affected, writing a press release, estimating the response level and customer service agent needs, considering regulatory reporting requirements, and determining the appropriate remedy.
5. Observe and record – Make note of how team members are working together, of any regulatory mandates the organisation didn’t understand, and note any gaps that may need to be filled by an outside party.
A recall scenario is bad enough, but botching the execution can cause serious damage to customer loyalty and put companies in danger of fines and legal liability. By preparing in advance, brands are in a better position to avoid these consequences and make it through a recall smoothly and efficiently.
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