This week, Charlie creates a checklist for you to follow in case of a product recall situation.
This week I carried out a product recall exercise for a pharmaceutical company. I do not claim to be an expert in the finer processes of a product recall, but some of the issues associated with product recalls are very similar to those associated with crisis management or business continuity. For this week’s bulletin, I am sharing some of my thoughts, and a checklist of actions that should be considered for recalling any type of product. The following are some issues you should consider.
1. Who will manage the incident?
Product recall plans, especially if they are a regulatory requirement, may be written by those unfamiliar with the incident management structure within the organisation. The plan may only be focused on the product control process, recalling the product, and informing those affected. It may not take into account dealing with the media, brand, and reputational requirements of the response. Sometimes the product recall plan could include members of the crisis team, and so they may be unsure which plan is being used as a response. Review what is in place and you may need to get the product recall team to work alongside the crisis management team to manage the response. The product recall team can deal with the technical elements and logistics of the recall, while the crisis team deals with external and internal communications, failure to supply to customers, and the associated reputational issues.
2. Check your quality assurance process
After a product recall, you need to quickly understand why the product has failed, and this may be found by checking the quality assurance process. You are looking to understand if the process was followed correctly and to see if any corners were cut. You may find a flaw in the process or a problem that could have caused the issues. On the other hand, you may find a flaw in the process which may have no impact on the product, but could be a deviation from the process. If you discover an issue, you can prepare your PR or messaging to take this into account, either to say why the incident occurred or to say there was a flaw, but this had no impact on the product at all. What you want to avoid is a member of staff, or perhaps a third party leaking the fact there’s a flaw in the process to the media or regulator. This may look like your organisation knew about it and then decided to cover it up.
3. Understand how a product recall decision is made and who makes it
Does the final decision on a recall rest with the organisation or the regulator? On what basis is a decision made and what should be taken into account? Does your organisation have appropriately qualified and experienced people to make the decision? How the decision is made should be documented, senior managers should be trained in understanding their part in the recall and the process should be exercised.
4. Exercise with partners
Often your products may be made in full or parts of it made by third parties. Good crisis management practice says that you should avoid blaming other parties in the middle of responding to an incident. There is the old adage in business continuity that “you can outsource the activity, but not the risk”. If it is your product that is faulty, customers will see it as your problem, not your supplier’s. Sometimes the supplier may be an obscure brand nobody has ever heard of, so this incident will have very little impact on their brand. On the other hand, the brand producing the product may be stronger than yours, the organisation may be larger and have more resources, so blaming them may have a strong reaction and you may not win the PR war. With partners, there is also the issue of how you will jointly manage the recall and the incident together. Will they send a senior manager to your incident room or video conference? Will they send a liaison person or will you run two separate incident teams? Do you know how to contact them out of hours to inform them of an incident? If they are a large organisation and you may be one of many parties affected by the incident, do you understand how you stand on their order of priority and will they deal with you as a priority? Or do they have a much larger customer who is more important than you? It is best to exercise these issues before they occur and then have protocols in place on how you will work with the supplier.
5. Think about risk and prepare
Perhaps initially your product recall has very little impact and no media interest, so you think you have “gotten away with it”. I think all organisations should do a dynamic risk assessment and look at a realistic worst case, best case, and most likely case scenario. Look at the worst case scenario, prepare for the incident and have appropriate communication at the ready. Make use of the time to prepare so you can react immediately and be on the front foot, rather than be reactive, which will lead to criticism within the media.
6. Think through your relationship with those affected
If your product was supplied to members of the public and it harmed them, think through how you are going to engage with those who you have harmed. You want to show you are empathetic, caring and you recognise the harm possibly caused by your product. However, at the same time you may not want to admit liability until the impact can be proven to be your product. This is a difficult line to hold, which requires careful communication, wording and briefing of spokespeople. This again should be practised and exercised. Having a legal representative or someone who understands the associated regulations should be considered to be on your incident team.
7. Who will provide scientific advice?
Product recall may require an in-depth understanding of the product and possibly the regulations they are supplied under. Organisations should think through who could act as a spokesperson for the organisation and they should have an appropriate understanding. They must be able to answer all ‘amateur’ questions, as well as in-depth technical questions. Senior managers within the organisation may not have this expertise. When I was in the water industry and responding to a major incident, the CEO was the spokesperson for the company and did the empathy bit, next to him was the Director of Operations who was able to answer any technical water and water quality issues. This combination of the two worked extremely well. If you are going to use a technical spokesperson, they should be media trained.
8. Use your website to provide detailed and technical information
If you need to provide technical or detailed information on your product, information on how the incident happened, questions and answers or what customers should do in response, then your website is a good place to put this information. Customers can self-service and those who need detailed information can find it. This could include product sheets, processes and details of the checks made before the product is supplied to customers. Newspapers and news sites are often short of journalists and if they can write a detailed story by lifting the information of your website, then they can get a detailed story for very little effort and you have an opportunity to put across your side of the event. Again, think through what information you would post on the website and if you have a huge number of products, practice how long it will take for you to put together this information.
9. Think through how you will protect your brand
If your brand is impacted by the recall, think through how you would protect it. The Tylenol product tampering case in 1982, where seven people died, is a classic case study of how withdrawing your brand from the market and then relaunching it with a number of additional measures to stop product tampering can actually enhance your brand. Scenario planning may be a good way of looking at how you would protect your brand under different circumstances. Having a PR firm on call or at least speaking to one in advance gives you the option of using crisis communications professionals and having their expert advice on how to deal with brand issues.
10. How will you deal with supply to customers?
If a batch of your product or your entire product has to be withdrawn, how are you going to continue to supply customers? There may be no substitute, so your customers may have to wait. There is the possibility of supplying your customers with a rival’s brand to ensure that they don’t go elsewhere, or if the brand recall is a small batch you can resell it from your other stock. This might lend itself either to scenario planning or an exercise where some of the issues, risks, and decisions can be explored.
Last of all, where is your plan? There are a number of particular issues associated with a product recall. Organisations that are creating a product recall plan should develop a checklist or prompts of how the crisis team will support the product recall team in terms of communications and reputation management. Those who haven’t got a plan should explore the risk associated with a product recall and should decide if developing their own plan is required. Plans when developed should always be exercised!