If you are a manufacturer, importer, distributor, or retailer of consumer products, you may need to conduct a product recall in the future. But is each department prepared and have a recall plan in place? Has it been tested across all departments, analyzed, and restested every six months to insure it is current? This represents a mock recall planning exercise. According the CPCS, “A well-thought out, well-executed mock recall plan can save lives and prevent injuries in addition to limiting damage to your company’s brand and bottom line.”
With the latest FDA Guidance published in March 2022, the essential need to be recall ready has bubbled to the surface. Although not required, do you want to be that company not prepared?
A mock recall plan can aid in the execution of an acutual product recall by apportioning duties, centralizing current contact information, and providing prewritten templates for communications. Key Individuals that will be participating in a company mock recall should review the recall plan and be familiar with the execution of the plan.
Mock Recall Planning TEAM APPROACHES
When developing a recall team you should consider two approaches.
- Uncover and Evaluate Team: This team uncovers and evaluates any potential product defects or deficiencies, BEFORE they result in damage or injuries. This team also should work on recommended fixes, if/when appropriate.
- Product Recall Team: This cross functional team is created, when developing a recall plan, that combines requisite skills, marketing savvy and experience to implement and periodically review product safety evaluation procedures, product recall plans, and product safety concerns raised internally or by external or governmental inquiries or complaints.
Mock Recall Planning TEAM ROLES THAT ARE TYPICALLY INVOLVED INCLUDE:
- Accounting
- Customer Service
- Distribution and Supply
- Information Technology
- Legal Counsel
- Maintenance
- Management
- Marketing
- Operations
- Production
- Public Relations
- Purchasing
- Quality Assurance
- Records Management
- Regulatory affairs
- Sales
- Sanitation
It is essential the mock recall management team be made aware of who they are as well as know their roles and responsibilities. This team should include subject matter experts (SMEs) both internally and externally that can offer their expertise at crunch time.
The basics should include a matrix of internal and external team members with their contact information which should always include what time zone they are in, their email as well as office and cell phone numbers where they can be reached 24/7.
It is also essential that when defining the matrix there is no duplication of efforts that can create confusion and conflicting objectives. This will allow for cohesion.
Ideally, the team should meet regularly to review all internal and public information, involving the product, and communicate any concerns.
Over the next 12 weeks, we will be exploring in detail each department’s and individuals’ role and responsibility, when conducting a product recall. We will then focus on mock recalls and training your team to see how the team carries out the roles and responsibilities.
Learn more about each department’s role during a product recall and mock recall exercises