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Product Recalls - Recall Coordinators

Designating a Recall Coordinator

The Consumer Product Safety Commission (CPSC) recommends that companies designate an official or employee as a "recall coordinator." The recall coordinator should have full authority to take the steps necessary to initiate and implement all recalls, with the approval and support of the company's chief executive officer. The recall coordinator should have the following qualifications and duties:

* Knowledge of the statutory authority and recall procedures of the CPSC.

* The ability and authority to function as the central coordinator within the company for receiving and processing all information regarding the safety of the company's products. Such information includes quality control records, engineering analyses, test results, consumer complaints, warranty returns or claims, lawsuits, and insurance claims.

* Responsibility for keeping the company's chief executive officer informed about reporting requirements and all safety problems or potential problems that could lead to product recalls.

* Responsibility for making decisions about initiating product recalls.

* Authority to involve appropriate departments and offices of the company in implementing a product recall.

* Responsibility for serving as the company's primary liaison person with CPSC.

The Role of the Recall Coordinator

The recall coordinator should fully review the company's product line to determine how each product will perform and fail under conditions of proper use and reasonably foreseeable misuse or abuse. Through research and analysis, product safety engineers can identify the safety features that could be incorporated into products that present safety risks to reduce their potential for future injury.

The company should institute a product identification system if one is not in use. Model designations and date-of-manufacture codes should be used on all products, whether they carry the company's name or are privately labeled for other firms. If a product recall is necessary, this practice allows the company to identify easily all affected products without undertaking a costly recall of the entire production. Similarly, once a specific product has been recalled and corrected, a new model number or other means of identification used on new corrected products allows distributors, retailers, and consumers to distinguish products subject to recall from the new items. Until a production change can be made to incorporate a new model number or date code, some companies have used sticker labels to differentiate products that have been checked and corrected from recalled products.

Copyright 2012 LexisNexis, a division of Reed Elsevier Inc.

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