2012 Safety Academy: Fast Track Program


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A panel comprised of a CPSC expert and a GE attorney discuss the agency's fast track process.

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2012 Safety Academy: Fast Track Program

  1. 1. U.S. Consumer Product SafetyCommission-2012 Safety Academy Fast Track Panel This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.
  2. 2. U.S. Consumer Product Safety Commission Safety Academy Office of Compliance and Field Operations Overview September 20, 2012 Tanya Topka Fast Track Team Lead, ComplianceThis presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.
  3. 3. Agenda• Reporting Under Section 15• Conducting a Fast Track Recall• Conducting a Recall• Monitoring Recalls
  4. 4. Reporting Under Section 15Covers both Fast Track and Non-Fast TrackWe encourage reporting under Section 15 on our website or via e-mail to the Section 15 mailbox. – Faster, easier to track and route – Add photos and other documents• On our website at: www.cpsc.gov • On right-hand side under “Businesses”• Or via e-mail to: Section15@cpsc.govWe discourage reporting via phone, mailed letter, or fax. – Much slower, harder to track, and much easier to get lost or duplicated during routing
  5. 5. Reporting Under Section 15 What to Provide When ReportingInitial Report• Details about product, stop sale date, potential defect and hazard, samples, and all available informationFull Report• All information (1-15), customer list, CAP, notice documents, draft press release, test reports, list of foreign countries sold to, reverse logistics/disposal plan• Compliance Lead assigns report and contact is Made Within 24 Hours
  6. 6. What is the Fast Track Program?• Initiated in 1995, it eliminates “preliminary determination” (PD) of hazard for cases reported by a firm that can quickly implement a recall.• WIN-WIN-WIN – Firm avoids PD and can implement a recall quickly – Staff expends less resources – Public gets quicker notice
  7. 7. What is the Fast Track Program?• Firm must do public notice and initiate a stop sale quickly.• Firm can do repair, replacement, or refund as corrective action. – Staff will review repair or replacement proposals before implementation.• Firm must still provide a Full Report and all requested information for a Fast Track recall.
  8. 8. Conducting a Recall Ways to Reach Public About a Recall• Hotline (toll-free)• Posters at traditional retail locations (several locations)• Forums, trade associations, magazines for industry, brochures, and catalogs• Direct notice is BEST (e-mail, letter, phone calls) – Review all internal customer lists (loyalty cards, warranty, catalogues)
  9. 9. Conducting a Recall Ways to Reach Public About a Recall• Website (initiate online registration, instructions)• Social media (Twitter, Facebook, Google+, Blogs) – Firms expected to announce recalls on their social media platforms – CPSC routinely uses Twitter• YouTube (recall message, how-to repair, step-by-step instructions, how to assemble)
  10. 10. Choosing a Remedy Refund/Replacement/Repair• Refund is the fastest and easiest method for consumers. – Must consider if product will be returned and how. – Removal of a piece that can disable product and be returned at lower costs. – Pre-paid postage return for consumers. – If not returned, consider form to sign for refund.
  11. 11. Choosing a Remedy Refund/Replacement/Repair• Replacement must be a comparable product. – Requires review of test reports/data by staff.• Repair programs always need staff review of data. – Can be done by consumer, technician, or return to firm. – If done by consumer, must be easy with clear instructions. – If tools required, should provide them.
  12. 12. Conducting a Recall• Press Releases – Recalls announced in press releases due to lack of direct notice and need for outreach. – Can be pitched to media, can be highlighted on CPSC’s main page, routinely tweeted – Can be embargoed
  13. 13. Conducting a Recall• Recall Alerts – Very small percentage of recalls – Still posted on CPSC website – Requires direct contact for virtually all consumers, retailers, and distributors – Must provide a customer list to qualify for a Recall Alert
  14. 14. Conducting a Recall How to Speed Up the Recall Process• Report electronically online or via Section 15 mailbox.• Provide all required and requested information; don’t make us ask for each missing item.• Provide Full Report electronically in numbered format (1-15), not in a narrative.• Provide samples, test reports, and engineering documents for repair or replacement programs early in process for staff review.
  15. 15. Conducting a Recall How to Speed Up the Recall Process• Provide press release in Word format.• Provide high-quality jpg photos of product.• Respond promptly to technical questions.• Flag issues to Compliance Lead.
  16. 16. Recall Monitoring Reverse Logistics• Reverse of distribution or product return – How you get product back from distribution• Reverse logistics plan should outline details such as: – How to quarantine the product – How to get the product returned – How to remove product from shelves – How to repair, replace, or dispose of product• Provide your reverse logistics plan to Compliance staff with your corrective action plan (CAP) and Full Report.
  17. 17. Recall Monitoring Reverse Logistics• Important process to plan and avoid having recalled products put back into distribution• Illegal to sell recalled products• Track, Track, Track – We need to know where your products are going at all times.
  18. 18. Recall Monitoring• CPSC staff monitors all recalls.• You must provide monthly progress reports via fax or e-mail until the case is closed by staff.• Use the progress report form provided with CAP letter. – Report incidents pre- and post-recall.
  19. 19. Recall Monitoring• We will check on implementation of the CAP through on-site recall checks with the recalling company, retailers, and consumers.• Notify Compliance of any changes at the firm or to the CAP. – New POC, new address or phone, hotline hours, bankruptcy or purchase
  20. 20. Recall Monitoring Ineffective Recalls• Notify Compliance if CAP appears not to have been effective.• Compliance staff may seek additional notification for post-recall incidents, ineffective notification, low correction rates. – Re-announcement of recall – Additional forms of notification – Out-of-season recall group notification
  21. 21. Recall Monitoring Disposal• Know if you will need special disposal for items like batteries or electronics (federal, state, or local laws).• If retailers will be disposing or destroying the product or if you are using a third party, we need to know.• Before you destroy, dispose, or recycle recalled products, notify CPSC staff via e-mail to recallproductdisposal@cpsc.gov.• Field staff may witness destruction/disposal/recycling or require an affidavit to verify process.• Notify us of plan as early as possible to coordinate field staff.
  22. 22. Recall Monitoring• Send a request to Compliance staff to close the formal monitoring of recall case.• Provide monthly progress forms until you receive a close letter from Compliance.• Continue to honor recall requests for remedy.• Continue to post recall notification on firm’s website after formal monitoring ends.
  23. 23. Need Information?• http://www.cpsc.gov/businfo/corrective.html• Tanya Topka, Fast Track Team Lead ttopka@cpsc.gov or 301-504-7594Defects Investigation Team Leads:Blake Rose- Fire, Electrical, and Mechanical Products brose@cpsc.gov or 301-504-7613Renae Rauchschwalbe- Children’s Products rrauchschwalbe@cpsc.gov or 301-504-7664
  24. 24. 2012 CPSC Inaugural SafetyAcademyCPSC Fast Track ProcessMichael Del NegroSenior Counsel, Product Safety & Regulatory ComplianceGE Appliances / GE LightingSeptember 20, 2012
  25. 25. Ensuring Coordination with the Officeof Compliance and Field Operations Organization Clear Communication Transparency Timeliness Anticipating (and minimizing) timing disruptions 30
  26. 26. Fast Track Best Practices Dedicated recall coordinator Cross-functional team (service, technology, communicatio ns, legal, product mgt.) – Assign tasks, owners and deadlines – Regular rhythm to manage unknowns Communicate to compliance staff to avoid disruption and ensure an effective recall Anticipate / manage potential recall challenges 31
  27. 27. Ensure Good Recall CommunicationCreative notification plans  Social media  Branded recall websiteCustomer Coordination Keys  Contact distributors early in process to identify potential consumers  Work around service-delivery issues 32
  28. 28. Managing “Recall Fatigue”Multiple sources of recall informationClear, technically accurate hazard descriptionsClassifying hazards? • Staff classifies hazards by severity • Could factor into timing • Useful to prioritizing highest risk events We want to prioritize and address highest-risk recalls to promptly eliminate such hazards 33
  29. 29. Challenges of Fast Track TimingLaunching within 20 working days of report • Uncontrollable events (suppliers, service) • Challenges with complex products • “Getting to Yes” on the joint press releaseKeys to success • Organization, clear communication and transparency 34
  30. 30. Consumer Product Safety• CommissionMr. Dean W. Woodard U.S. CPSCDirector Office of Education, Global Outreach, and Small Business Ombudsman dwoodard@cpsc.gov business@cpsc.gov