Expert Recall

By Howard Aughinbaugh

The Consumer Product Safety Commission announced on December 24, 2009, that the agency voted unanimously on registration requirements for durable infant or toddler products. While we’ve previously mentioned the new rule on this blog, as recall experts we want to ensure it receives the attention it deserves. This new rule creates one more path to follow to achieve regulatory compliance, while also affecting the entire recall planning and communication process.

So what does the rule entail? This rule will affect 18 categories of infant and toddler products including cribs, chairs, play yards and activity centers. According to the CPSC, the final rule requires manufacturers comply with the following:

1. Provide a postage-paid consumer registration form with each product;
2. Keep records of consumers who register their products with the manufacturer; and
3. Permanently place the manufacturer’s name and contact information, model name and number, and the date of manufacture on each product.

The final rule will also specify the text and format for the registration form as well as establish requirements for online product registration.

We agree with the CPSC’s assessment that this will help companies better communicate with consumers about recalled products – but it’s no panacea. Many of the big ticket nursery items this rule affects, like cribs and strollers, are often passed down from one generation to the next without assembly instructions or the appropriate product warnings. This leaves registration cards outdated, or possibly missing.

Just because your company adheres to this rule – which it must in order to be compliant – doesn’t mean you’re ready for a recall. Recall risk is still real. This new rule is only one of many that you must adhere to before, during and after a recall event to ensure you quickly and effectively protect your customers and close out a recall.

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.