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This article was sponsored by the Office for Product Safety & Standards
As a UK business, you take pride in the products that you produce. But despite following stringent manufacturing and quality control processes, you might need to recall a product on safety grounds. How can you anticipate and deal with those incidents?
If you don’t fully understand what needs to be done if something goes wrong, the first ever Government-backed Code of Practice for product safety recalls in the UK was created to support you, and for the first time, it will be available free for all small and medium sized enterprises (SMEs).
What is the Code?
On 7 March this year the Office for Product Safety and Standards (OPSS) and the British Standards Institution (BSI) launched ‘PAS 7100 – Code of Practice on consumer product safety related recalls and other corrective actions’, to make sure that businesses understand what they need to do if product safety issues arise.
PAS 7100 was the first major initiative for the OPSS, which was launched by the Department for Business, Energy and Industrial Strategy (BEIS) in January 2018. It follows a recommendation by the Working Group on Products Recalls and Safety, commissioned by the Government to introduce practical guidance for both businesses and local authorities, to assist businesses in being prepared to deal with consumer product safety incidents that might arise following the marketing of products.
The Code details how manufacturers, importers and distributors can plan for product safety incidents. It also sets out the guidance and advice that local authorities should make available to businesses to help them meet their legal responsibilities and take any action needed to protect consumers.
It was created together with leading retailers, consumer interest groups and industry bodies, including Tesco, Samsung Electronics, British Retail Consortium, Chartered Trading Standards Institute, and the Association of Chief Trading Standards Officers.
Why was PAS 7100 created?
Andrew Butler, Head of Protection at Hertfordshire County Council, who represented the Association of Chief Trading Standards Officers on the Steering Group when the Code of Practice was drafted, says that it was created to ensure that businesses can react in a proactive rather than reactive manner when dealing with product safety issues.
“There was a feeling that existing guidance didn’t really provide enough clarity about what a good product recall or corrective action looked like,” explains Andrew. “There was a huge variation in the way safety issues were dealt with by different businesses and a need for a more consistent approach to drive up response rates from consumers. The important thing now is that businesses take action to plan for a potential corrective action and not wait until a product safety issue arises.”
Phil Owen, Service Director, Chartered Trading Standards Institute, says that the Code is a practical guide which creates a “consistent and level” playing field: “The PAS 7100 will change the way we ALL view risk and recalls in that recalls should become the ‘norm’ and not something to be feared. It’s all about building better, stronger relationships between Local Authorities and businesses, and between Local Authorities and the OPSS and other partners.”
Gordon Maddan, Assistant Director – Business at OPSS, says that the value of the guidance is that it allows businesses to plan ahead: “Product recalls and other corrective actions present complex management challenges for any business and of a type they are not likely to experience very often. Thinking through in advance how the safety performance of products is monitored, how products can be traced and how incidents will be dealt with enables businesses to respond efficiently and effectively,” he explains. “Businesses should use PAS 7100 to help develop a Product Safety Incident plan (PSIP) so they are ready to deal with any product safety incident that might arise.”
What’s in the Code?
The Code of Practice comes in two parts. The first part focuses on non-food consumer products and is for use by manufacturers, importers and distributors. It details:
- how businesses can plan for a recall, including determining methods to deal with any identified product safety issue
- how to manage a possible safety related product recall or other corrective action
- how to create methods to monitor the safety of products
- how to investigate any potential product safety issue
- reviewing corrective action programmes to make sure that product safety responsibilities are met.
The second part is aimed at regulators, such as local authority trading standards teams. It sets out how they can help businesses to meet their responsibilities around consumer product safety issues by:
- monitoring incidents and analysing data
- supporting businesses in the preparation of a PSIP
- supporting businesses in their monitoring of incidents and the implementation of appropriate corrective action.
Gordon asserts that the guidance presents the opportunity for real change: “There is no silver bullet to improve the effectiveness of product recalls, but the wealth of guidance in PAS 7100, having been put together by front line product safety experts from business, enforcement and legal disciplines, makes best practice readily accessible to all businesses which should lead to an overall step change in performance.”
The Code is now free to all SMEs and available online here.