Expert Recall

By Mike Rozembajgier

There has been a lot of talk lately about whether Toyota’s recalls were effective. That is to say, did Toyota recall its vehicles at the right time, for the right reason, and with sufficient consumer response. While this may sound like a simple calculation, there is a lot that goes into the determination, including the number of products affected and the supply chain and location of product in the marketplace. As a result, there is no simple answer to the question, “When is a recall considered effective?” That said, there are a few things that you can do to ensure that your recall sufficiently notifies consumers and consignees and gets the response you need in order to close out the recall as quickly as possible.

Vehicle manufacturers have a distinct advantage over manufacturers of other types of products when it comes to contacting consumers. Car dealerships keep accurate records of who bought each vehicle and can make reasonable attempts to contact them. If the vehicle has changed owners, there is still a chance that the car is serviced by a dealer familiar with the make or model who can make any necessary recall-related fixes during routine maintenance or annual car inspections as required by state governments.

When it comes to Toyota, recent reports suggest that the automaker has made about 80 percent of required repairs to U.S. vehicles affected by the sticky accelerator pedal recall. Toyota has also reportedly repaired about half the vehicles impacted by the floor mat recall. We can also reasonably assume that these numbers will continue to increase given the recall mechanisms available to automakers. While it seems Toyota has a strong handle on their recalls and are getting the response they need, it is up to NHTSA to ultimately determine whether the process is moving as fast and efficiently as the agency requires.

On the other hand, getting a 50 to 80 percent response rate is not always so easy for other product manufacturers. Given the complications involved with contacting consumers and consignees to notify them of a recall, it is critical that you understand the expectations of whatever regulatory agency would oversee your recall. And because there is no distinct formula for determining the effectiveness threshold for your specific recall, you should consider conducting your own effectiveness checks throughout the recall process so that when regulators are deciding whether you can close out the recall, you can provide documentation supporting your assertion that the recall was effective.

To do this, you must know that there are two critical areas the agency wants to see handled effectively – call center operations and removal of products from store shelves. The agency wants to be certain that a company’s recall communications system is providing consumers and retailers with a resource for getting their questions answered. And regulators want to be absolutely certain that products are off shelves and out of commerce.

Recall effectiveness is a tricky, but essential, concept to understand. While there are ways you can increase your recall effectiveness, you may also want to have a third-party advocate and recall service provider on your side, someone who understands industry standards and norms when it comes to recall response rates to ensure the expectations of the regulatory are feasible given your particular circumstances. It all comes down to being prepared and having the resources you need beforehand so that you can execute and close out the recall as quickly and smoothly as possible.

Stericycle ExpertRECALL™ is the industry leader in recall logistics and regulatory compliance for consumer product, pharmaceutical, medical device, juvenile product, and food and beverage recalls. ExpertRECALL’s professionals are experts in recall management who can help you streamline the entire product recall process.