There are some steps that you should take urgently if your
company finds itself the subject of a product recall or if you suspect that
there is a serious safety or product efficacy issue to deal with.
Capture field and factory information about faults: what are
they, how many are there, when were they discovered, what are the batch details?
Collect as many samples as possible, take photographs, find inspection
reports, identify common factors, identify the affected population.
Beware of admissions in internal or external documents, including
emails, before position is established and advised on.
Once enough information is available assess the likelihood of
injury and the likely severity.
Once there has been a risk assessment and lawyers have
advised, consider whether you are obliged to notify a regulatory.
Be prepared to advise what corrective/recall action is being
taken and why or why none is appropriate.
Involve your lawyers from the start to guide on:
safety and recall obligations;
use of privilege to avoid open admissions that
can be used against you
use of privilege to cloak fault investigations
documenting fault and scale for loss recovery or defence purposes
clearance of PR releases/announcements/recall
If the issue is likely to be large scale or serious, involve
PR professionals to support communication with press, customers and government.
Ensure that a point of contact for all media enquiries is established and brief
all staff, including those answering phones, to direct all queries to the point
Consider material to include on website.
Notify any liability or recall insurers urgently. Seek to
keep insurers abreast and bought in to any recall activity.
Assemble a senior crisis team to be responsible for and to
coordinate the handling of the issue.
Consider quarantining product that is suspect in a factory, warehouse
or distribution chain while information is gathered and assessed.
Recover and store in conditions where it will not degrade
fault examples or all recalled product if possible and practical to evidence
any recovery claim.