1. U.S. Consumer Product Safety
Commission-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. U.S. Consumer Product Safety
Commission
Safety Academy
Office of Compliance and Field Operations Overview
September 20, 2012
Tanya Topka
Fast Track Team Lead, Compliance
This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect
the views of, the Commission.
3. Agenda
• Reporting Under Section 15
• Conducting a Fast Track Recall
• Conducting a Recall
• Monitoring Recalls
4. Reporting Under Section 15
Covers both Fast Track and Non-Fast Track
We 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.gov
We discourage reporting via phone, mailed letter, or fax.
– Much slower, harder to track, and much easier to get
lost or duplicated during routing
7. Reporting Under Section 15
What to Provide When Reporting
Initial Report
• Details about product, stop sale date, potential
defect and hazard, samples, and all available
information
Full 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
8. 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
9. 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.
10. 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)
11. 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)
12. 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.
13. 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.
14. 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
15. 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
16. 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.
17. 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.
18. 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.
19. 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.
20. 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.
21. 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
22. 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
23. 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.
24. 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.
28. Need Information?
• http://www.cpsc.gov/businfo/corrective.html
• Tanya Topka, Fast Track Team Lead
ttopka@cpsc.gov or 301-504-7594
Defects Investigation Team Leads:
Blake Rose- Fire, Electrical, and Mechanical Products
brose@cpsc.gov or 301-504-7613
Renae Rauchschwalbe- Children’s Products
rrauchschwalbe@cpsc.gov or 301-504-7664
29. 2012 CPSC Inaugural Safety
Academy
CPSC Fast Track Process
Michael Del Negro
Senior Counsel, Product Safety & Regulatory Compliance
GE Appliances / GE Lighting
September 20, 2012
30. Ensuring Coordination with the Office
of Compliance and Field Operations
Organization
Clear Communication
Transparency
Timeliness
Anticipating (and minimizing) timing
disruptions
30
31. 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
32. Ensure Good Recall Communication
Creative notification plans
Social media
Branded recall website
Customer Coordination Keys
Contact distributors early in process to identify
potential consumers
Work around service-delivery issues
32
33. Managing “Recall Fatigue”
Multiple sources of recall information
Clear, technically accurate hazard descriptions
Classifying 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
34. Challenges of Fast Track Timing
Launching within 20 working days of report
• Uncontrollable events (suppliers, service)
• Challenges with complex products
• “Getting to Yes” on the joint press release
Keys to success
• Organization, clear communication and
transparency
34
36. Consumer Product Safety
•
Commission
Mr. Dean W. Woodard U.S. CPSC
Director Office of Education, Global Outreach, and Small
Business Ombudsman
dwoodard@cpsc.gov
business@cpsc.gov