Chemical Flame Retardants Debate

The debate over the use of flame retardant chemicals in consumer products is again raising its head.  This debate has been going on for more than 30 years.  Studies are being conducted all over the world on the effects of chemical flame retardants on the environment and on humans.  There have been studies indicating that some of the chemical flame retardants such as chlorinated tris are being absorbed through our skin.  As far back as the late 1970’s the Consumer Product Safety Commission banned the use of chlorinated tris in children’s sleepwear due to studies confirming that the chemical caused cancer in lab animals and that it could be absorbed through skin.  Since the ban was specific to children’s sleepwear and it wasn’t an overall ban on chlorinated tris, the chemical is still used in many other products today.  More recent studies found traces of chemical flame retardants in tree’s in very remote areas of the world indicating the ability for the chemicals to be carried by air or water are wide spread.  There have also been studies that indicate chemical fire retardants could be linked to lower I.Q. scores in children even possibly a contributing factor to obesity.  In reaction to the concerns that are being raised, Maryland has passed a bill to prohibit the sale of children’s products made with a form of chlorinated tris and it is currently awaiting their governor to sign it into law.  Since January of this year, 12 other states have begun to consider bills restricting the use of flame retardant chemicals.  As these laws are passed, manufactures will need to continue to review them and determine the appropriate course of action.  Don’t forget to update your product safety and recall procedures as you make changes to comply with the new regulations.

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Our quest for more power can pose a safety risk.

As technology has increased so has consumer demand for the technology to be portable.  We have reached a point where a typical portable computer is more powerful than the supercomputers of 20 years ago.  The work demand of the computer generates heat.  The more work completed the more heat is generated.  We now have devices that are small enough to sit on our laps and are capable of doing the same amount of work as a device that took up about 100 square foot and had a liquid cooling system to help reduce the heat.  As the portable devices don’t have an external liquid cooling system, what becomes of that heat?  Our new devices require less energy to do the same amount of work so they don’t generate as much heat but they still produce a significant amount of it.  In an attempt to extract the heat from the device, manufactures use fans and exhaust ports as well as applying heat transferring materials inside the devices.  So what happens when the exhaust ports get blocked?  That heat becomes trapped inside the device which could have severe consequences.  We see reports of this on an ongoing basis which have resulted in minor burns and even fires.

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Is there a better way to reach consumers about a recall?

Over the last 15 years, there have been many different avenues attempted when it comes to reaching consumers with information about a product recall.  Currently, the talk is about how to harness the power of social media to target consumers with recall information.  There are many websites and social media groups that post information about all recalls.  Anyone who wishes to receive notification about all recalls can subscribe to the release of CPSC & FDA.  With all of these sources of information available, the method I still find the most effective is direct consumer notification.  Whether by e-mail or by letters sent through USPS, notifying the consumers who purchased the product directly is the most productive way of getting consumers to comply with a recall notice.   There is just something about that personal touch and call to action that always generates response.

 

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Your Recall Plan is your Cycling Trainer

Being an avid cyclist, it has always amazed me how quick you lose the performance gains over the winter that you worked all riding season to achieve.  Unfortunately exercise bikes and stationary indoor trainers don’t give you the same workout as actual riding.  Roller trainers provide a better alternative as they force you to use the same muscle groups as in addition to just peddling, you must balance the bike to prevent falling as there is nothing affixing the bike to the trainer.  I feared roller trainers for years.  My fear was not the skill required for use, it was the unknown of what happens if something goes wrong with the trainer.  I had visions of a roller failing causing me to careen off the rollers and smash head first into a wall.  Two years ago, my wife forced me to face this fear by purchasing a roller trainer for me.  I still have a bit of fear but, not losing all of my performance gains from the previous season outweighs this fear.

Similarly, I believe there are a lot of manufactures that have resisted product recall preplanning for the fear of the unknown.  This is causing a loss of performance gained by their product advances when a recall occurs.  By waiting until you have a recall staring you in the face, you are forced to scramble and play catch up.  Having a documented and tested recall plan will keep your business running smoothly when you’re faced with a recall.

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Quest for Power Compromising Safety

The world has changed quite a bit over the last 30 years thanks to technology.  As technology has evolved, we continue to demand products that are smaller, lighter, faster, and have a long battery life.  Over this time period there has been a lot of research and development in battery technology to keep up with these demands.  If we look at what have become our technology staple, cellular telephones, over this time period, we see a large amount of change in just battery technology.  In March 1983, when Ameritech launched the first US cellular telephone network, the portable phones were large bulky packs that weighed several pounds, had batteries that lasted 30 min.’s and took 10 hours to recharge.  In contrast, today’s typical cellular phone weighs ounces, the batteries last a full day and they take less than an hour to fully recharge thanks to the invention of Lithium-ion batteries.  They are smaller, lighter and have the capacity to hold a large amount of energy.  These batteries power a large percentage of our devices and have been in the news quite a bit lately.  Unfortunately, as with all creation or use of energy, the byproduct is heat, there is no getting around this.  Just like our bodies produce excess heat when we exert energy working or exercising, any other object that produces or uses energy does as well.  We continue to see reports of batteries catching fire in electronics, cars, and most recently airplanes.  Is our quest for smaller, more powerful, longer lasting devices compromising our safety?

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Counterfeit Products

In the last several years, there has been an increase in product counterfeiting.  Some of the counterfeits have gotten so good, marketing staff of manufacturers are having a difficult time distinguishing their product from the counterfeit by looks alone.  Consumer product counterfeiting is nothing new, it’s been going on for decades.  What is new is the type of products being counterfeited and the distribution tactics.  It has been common to see counterfeit name brand shoes, jewelry, clothing and fashion accessories but now we’re beginning to see counterfeiters venture into products such as pharmaceuticals, household cleaners, and other every day products.  Their distribution has become so sophisticated that it’s possible for counterfeiters to get their products on the shelves of the stores we shop every day without anyone noticing.  Counterfeit products cost manufacturers more than sales revenue.  As the products typically contain inferior substances and sometimes cause adverse reactions with the users, manufactures end up spending a lot of time and money investigating the fraudulent product and defending their selves.  In many cases, manufactures have issued recalls on counterfeit products to not only clear their name but to protect their customers from these sometimes harmful products that have been sold as theirs.

One important piece to assist manufactures in catching counterfeit products is their product recall plan.  Having a recall plan that includes how to monitor and investigate consumer complaints is the initial key to finding and eliminating counterfeit products.  A sudden increase in consumer calls and / or complaints regarding a product that has had no material changes is a red flag that must be investigated quickly and thoroughly.

Does your product recall plan contain the steps necessary to help you detect counterfeit products?

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Foreseeable Misuse

When dealing with product recalls there are 3 general categories that you can apply to the recall, Design Defect, Manufacturing Defect, and Foreseeable Misuse. Design and Manufacturing defects are fairly clear categories but Foreseeable Misuse has a lot of gray area. When reviewing a new product or a design change, your product safety team must try to come up with not only how a consumer should use a product but how the consumer could use a product for unintended purposes and what are the potential consequences of that misuse. There is an unsubstantiated urban legend that has been circulating for many years of a consumer injured using a lawn mower as a hedge trimmer. Even though this may seem illogical, it’s these extremes you need to consider and document during your review. You also need to ensure your customer service representatives are documenting and reporting to your product safety team any type of unusual use of your products commented on by your customers.

Does your product safety and recall plans ensure that these actions are being documented and reported? If not, think about the potential risk you’re taking and contact us to discuss your product safety & recall plan needs.

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CPSC Releases Tip-Over Injuries Report

CPSC has just released their 2012 Product Instability or Tip-Over Injuries and Fatalities report, http://www.cpsc.gov/library/foia/foia13/os/tipover2012.pdf . The report looks at reported injury estimates between 2009 and 2011 and reported fatalities between 2000 and 2011 for instability or tip-overs with furniture, televisions, and appliances.

The injury section of the report shows that nearly 250,000 people were treated in emergency rooms for product instability or tip-over injuries between 2006 and 2011. 59% of these injuries involved children under the age of 18. The report breaks the injuries out in to three product types, Televisions, Only Furniture, & Appliances.  The report indicates that there were 39,100 emergency room reported injuries in 2006 and 40,100 in 2011. Furniture tip overs continue to make up the largest percentage of injury reports followed closely by televisions.

The fatalities section of the report shows similar statistics. Of the 349 fatalities reported to CPSC between 2000 and 2011, 84% involved children under the age of 18. For fatalities, televisions make up the largest percentage (62%) with furniture being second (30%).  There were 31 reported deaths in 2006 and 41 reported in 2011, a 32% increase in the last 6 years.

Over the past six years, there have been a number of highly-publicized child fatalities due to television tip overs. In addition, the industry has been working to educate consumers on the hazard of tip overs, and manufacturers have begun to include anti-tip devices and anchors with their products. What’s surprising is that even with all this effort, there has been no significant positive change in injury frequency in the last six years.

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Reaching the Product Safety Podium

Cycling has been in mainstream media quite a bit lately with the doping scandal and investigation involving Lance Armstrong. In reading all of the reports about the USADA investigation and the quotes from all of the riders, I hope people are beginning to understand that cycling is a team sport. Often, someone who is unfamiliar with cycling will read about the rider who wins the Tour de France and take it at face value that it was the individual who won. Without the support of his team, lead riders would never reach the podium. It’s the team plan that helps ensure that every member plays his role and ensures that the team goal is achieved. The team plan goes well beyond the riding and training strategies all the way down to the physical, mental & medical preparation. Just like cycling, product safety is a team effort. It takes cooperation from every member of the organization to put the plan together and ensure that the best and safest product gets produced. Without the effort of the entire team, and a well document and laid out product safety plan, the product goal cannot be reached.

What happens if an adverse event prevents the designated rider from continuing the race? The team has a contingency plan that they immediately implement so they can quickly recover and return to focusing on the team goal. In product safety, we call this our Product Recall Plan, and as in cycling, it needs to be detailed, tested, and ready to go immediately if an adverse event happens with a product. Like the medical team that takes over and cares for the cyclist, the recall team members take over the focus on the product that needs to be recalled so that the team can continue to move forward.  Sometimes this is an internal team, other times this is an external team. Don’t be afraid to call upon an experienced, well trained external team to help you with a recall. Product Recalls can become messy and time consuming. By letting an external team take over the care of the recall, your internal staff can reengage in the company focus and put your team on the podium.

Dan Hinkebein, Manager Recall Business Services

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What’s in a Product Recall Name?

Over the last 15 years that I’ve been working with manufacturers with recall programs, I’ve heard many terms thrown about for Product Recalls. There has been a lot of creativity employed to avoid the use of the word Recall. This has led to a lot of confusion for product safety professionals.

I remember speaking to a young product safety manager, who had recently joined a company. He told me that one of the things they were very proud of at his company was that they had never had to recall a product. As I was familiar with the company and familiar with a few recalls they issued over the years, I was puzzled by that statement. I asked him about a sizable recall the company had facilitated just a couple years prior to his joining the company. Later, he spoke with his manager who promptly told him that it was a “Product Replacement Program” and not a “Recall” as they did not take the old product back. Instead they had the customer discard the product and sent a replacement product to the customer. His manager also explained that they had conducted several replacement programs, but because they never had customers return the product, they had never had a recall. I wish I could say that this is an isolated incident, but it’s not.

There are many product safety people who truly believe that if the customer is not returning the entire product to them, they are not “Recalling” the product. They use terms such as Corrective Action, Retrofit, Replacement, Modification, etc. In recent times, CPSC has made a change and no matter what you want to call it internally, the news release they send say’s RECALL. Does the verbiage really make a difference where it counts, in the effective rate of the campaign? I’ve not personally seen a difference in the correction percentages whether the campaign is titled Recall or something else. What I have seen it do is help product safety professionals understand that the word “Recall” is not as bad a word as their marketing team may have led them to believe.

-          Dan Hinkebein, Manager Recall Business Services

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California Safer Consumer Products Regulations: An Update

At a recent conference, there was a panel discussion regarding the state of California’s Safer Consumer Product Regulations, AB1879, also referred to as the California Green Chemistry Initiative. As part of the regulation, a “Gray” list of chemicals will be created. If a product contains one of these chemicals, in order for the product to be sold in the state of CA, the manufacture must report as to why the chemical is present in the product and defend that it is necessary for the chemical to be present. The regulations are currently being reviewed; the current version is dated October 2011. The good news is that regulators are attempting to take into account other regulatory programs such as Prop 65 and CPSIA so that AB1879 does not duplicate any of the other regulations. The not so good news, and most puzzling, is that they intend for the regulation to go into effect but they don’t expect to have any information on how manufacturers are to comply with the regulations for at least 6 months after the effective date.

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CA Prop 65: A Brief Q&A

I recently had the opportunity to attend the American Apparel and Footwear Associations Product Safety and Sustainability Seminar. One of the panel discussions was on California’s Proposition 65. It seemed like a good opportunity to review this important ruling that plays an important role in California product safety law.

What is Prop 65?
Prop 65, is the Safe Drinking Water and Toxic Enforcement Act of 1986. It is administered by the office of Environmental Health Hazard Assessment (OEHHA) which is part of the California Environmental Protection Agency. Prop 65 is a collection of about 670 state bills for regulating different chemicals and particles in products. Prop 65 requires that persons doing business in California may not expose individuals to chemicals known to cause cancer and/or reproductive toxicity without giving clear and reasonable warning. There are currently over 850 chemicals on the high risk substance list. Of these, about 300 chemicals have specific thresholds known as safe harbor numbers to guide manufactures in determining if a warning on the product is necessary. Most of the regulations under Prop 65 focus more on exposure risk than content.

Who is impacted by Prop 65?
Anyone who sells or distributes any product in the state of CA as well as anyone with a place of business, rental property, etc. in the state of California must comply with Prop 65.

How is Prop 65 enforced?
Unlike most other product safety regulations, Prop 65 is not enforced by any governmental regulatory agency. It is enforced when legal action is brought against a business. Any party, acting in the public’s interest, can send a manufacturer a notice letter alleging that the business is in violation of Prop 65. This letter, known as a 60-day notice letter, must be sent to the business 60 days before the party may file suite for the violation. In addition, the CA Attorney General or a district or city attorney may initiate the notice and file suite. Penalties for violation can range as high as $2,500 per day. As such, many of the Prop 65 complaints are filed by private attorneys who have built their business entirely on filing Prop 65 lawsuits.

What is the current focus of Prop 65 regulators?
Phthalates make up the largest focus of enforcement currently. This is followed by Lead and Cadmium.

Dan Hinkebein,

Manager Recall Business Services

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Once a Saving Grace Now a Health Risk

Over time, there have been a series of high-profile products that when initially introduced were marketed as providing vast benefit for consumers only later to be labeled as harmful and banned. The first product to fit this mold was lead based paint. As a kid I remember lead paint being promoted as a high quality product that was durable, fast drying, and corrosion preventive. Growing up in a construction family, we used a lot of it. Then in 1978, the US banned the product after determining that lead paint created a risk of lead poisoning to children who might ingest chipped or pealed paint.

The next product to follow this pattern was Asbestos. Asbestos has been mined and used for over 4,000 years, but it didn’t become a large scale commodity until the late 19^th century when it first began being used for insulation, sound absorption, and fire prevention. Documented health issues and deaths related to asbestos go back as far as the early 1900’s. In the 1980’s the EPA began investigating asbestos content in products sold in the US which led to an attempt by the EPA to ban Asbestos and issue phase out rules. The ban was overturned by the case of Corrosion Proof Fitting v. EPA in 1991. The result is that there are a few product categories in which asbestos is banned, but we have no actual ban on the overall use or importation.

The newest product to follow this pattern is flame retardants. Chemical flame retardants have been used in everything from clothing to furniture for many years. They were introduced to slow the burn of materials that would typically burn rapidly to help reduce injuries and loss of life in the event of a fire.  Polychlorinated biphenyls (PCBs), which were the earliest flame retardants, were banned in 1977.  Alarming reports are now surfacing showing that chemical flame retardants are being found in our food supply and within our body’s. California Governor Jerry Brown directed his state agencies to revise flammability standards with a goal of reducing toxic flame retardants.

Are there other products that will follow this cycle?  Only time will tell.

Dan Hinkebein,
Manager, Recall Business Services

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CPSC Considering Civil Penalties for Failure to Report Product Safety Issues

Federal law requires that a company report to CPSC within 24 hours of obtaining information that reasonably supports the conclusion that a product contains a defect which could create a substantial product hazard, creates an unreasonable risk of serious injury or death, or fails to comply with any consumer product safety rule or any other rule, regulation, standard, or ban enforced by CPSC.

In her address to the attendee’s at the annual International Consumer Product Health & Safety Organization (ICPHSO) 2012 conference in February, CPSC Chairman Inez Tenenbaum announced that the commission is looking at previous recall campaigns to assess if each company in fact reported the issue to CPSC in a timely manner. Since October 2011, CPSC has issued Civil Penalties totaling more than $3.5 Million Dollars to five companies because an investigation revealed that the companies had evidence or reports of potential safety or compliancy issues and did not report to the CPSC within the parameters of the reporting laws.

The only way for companies to ensure that reports of product failures and incident are properly handled is for the company to have a well-documented and followed product safety and recall plan. Without a plan, your company could be at risk for these types of penalties if you face a product safety issue. Need to know more or have questions, contact us for a free consultation.

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Product Recall Insurance Policies – Does It Make Sense?

Over at the American Bar Web site, there is some useful discussion on the value of Product Recall Insurance Coverage. This type of coverage can provide for protection from product liability claims as well as for the extra expenses associated with a product recall. The article provides an overview of the different types of policies and discusses some overall suggestions for product safety preparation. You can read the entire article here.

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Your Product Recall Plan is your Company’s Bicycle Helmet

As bicycling has been getting more attention worldwide, the bicycle safety debate continues to heat up.  There is a lot of debate around the world about bicycle helmet laws.  As an avid cyclist, I personally do not ride without a helmet.  To me it’s common sense.  In the event of an accident, the risk of severe injury or death is reduced by wearing a helmet.  Should there be mandatory helmet laws?  I don’t know.   I ride a couple of different group rides each week.  Everyone in the groups I ride with share my view on helmets.  However, we see quite a few others that don’t.

There is a similar situation with consumer product safety.  With the exception of the food and beverage industry, there is no law that requires most manufacturers to have a documented recall plan in place.  This is like bicycling without a helmet.  If a situation arises and you find you need to recall a product what do you have to protect your business and ensure that the recall is handled properly?  What do you do to recall the product?  How do you handle it?  The company goes into crisis mode and rash decisions are made that can cost a company valuable time and money.  With a well detailed product recall plan in place that is followed by all departments, the strain of facing the recall of a product is greatly reduced.

Just like a bicycle helmet, a recall plan is there to protect you during an adverse event.

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CPSIA and Apparel Manufacturers – A Work in Progress

The Consumer Product Safety Improvement act of 2008, or CPSIA, was a congressional reaction to public outcries following the large number of toy recalls in 2007. The reason for the 2007 spike was primarily due to excessive levels of lead in violation of the federal lead paint standard. The act established new, lower acceptable levels of several substances used in manufacturing of consumer goods and set forth the requirement of testing and certification of compliance. It was indicated at the recent American Apparel and Footwear Associations Product Safety and Sustainability Seminar that the act has unintentionally heavily affected the apparel and footwear industry. Many apparel products that were previously not required to be tested because the items do not typically contain hazardous materials now require testing under CPSIA. The CPSC has been working with the apparel industry since the enactment of CPSIA to draft guidelines and provide specifics as to what the industry needs to do to comply with these new regulations. It was clear at the seminar that there is still a long way to go for CPSC to help apparel manufacturers understand and ensure that they can affordably comply with the testing and certification regulations set by CPSIA.

A Spokesperson from the CPSC at the conference indicated that the agency’s key priorities for the apparel industry are flammability, the ban on drawstrings, and lead testing. All periodic product testing plans and certifications for lead must include sufficient testing to assure compliance and the spokesperson reiterated that testing records must be kept for five years.

In parting, the CPSC representative noted that they are currently watching for and going after manufacturers who are intentionally trying to get around the new restrictions on sleep wear by labeling the products as kids lounge wear.

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Product Recall Insurance Policies – Does It Make Sense?

Over at the American Bar Web site, there is some useful discussion on the value of Product Recall Insurance Coverage. This type of coverage can provide for protection from product liability claims as well as for the extra expenses associated with a product recall. The article provides an overview of the different types of policies and discusses some overall suggestions for product safety preparation. You can read the entire article here.

 

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WeMakeItSafer.com Provides Useful Tool for Consumers to Identify Recall Products

There’s a new Web site (still in Beta) at WeMakeItSafer.com that provides consumers a useful tool for identifying products that have been recalled. It’s also a useful tool for anyone looking for statistics and information related to recall activity.

The site includes a search engine to look for recalled products. There is also a unique tool that lets consumers create a catalog of their products as they review them for recalls. The tool then monitors the products over time for any future issues. This is a group really focused on product and consumer safety. Check it out today.

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Assessing Product Recall Effectiveness

How effective are product recalls in attaining stated goals? It’s a hot topic for those in the product safety world, and a question that is a focus for the Consumer Product Safety Commission (CPSC). The Product Safety Newsletter has a detailed discussion on this topic reviewing past history and different approaches. It’s an informative read if you have an interest. Some highlights:

1. Experts still debate the best approach to measuring success, for example number of products returned/repaired versus number of potential hazards eliminated.
2. Measuring actual effectiveness can be very difficult.
3. Actual consumer response rates can be very low.

The article also discusses the effectiveness of different approaches. You can read the entire article here.

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Well Managed Product Recalls Can Increase Brand Loyalty

You might think when something goes wrong and a product recall is required, that the best course of action would be to handle the incident as quietly as possible. It turns out the opposite is true. That’s the finding from a study conducted by several groups to evaluate the impact of product recalls on brand equity. The study looked at ten national brands including Tylenol, Toyota and Travelers Insurance.

According to the study, 93% of respondents indicate that a product recall reveals the “true colors” of a company or brand. Eight seven (87) percent say they are more willing to purchase from a company that handles a product recall honestly and responsibly. You can read more details from the study here.

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New Food Safety Law Makes Product Recall Plan Mandatory for Food Manufacturers

The Food Safety and Modernization Act (FSMA), which was signed into law by President Obama on January 4, 2011, grants new authorities to the Food and Drug Administration (FDA) to regulate the way foods, are grown, harvested, and processed.  Under the new law, FDA also has greater authority to access facility records, which will require additional steps for growers, processors, distributors and retailers to track the food and beverage products they handle.  The different components of the act are set up in a gradual sequence for implementation.   The deadline for any company that handles food or beverage products to have their documented safety plans in place is July 2012.  Part of the requirements of this portion of the act is that all companies will be required to conduct a hazard analysis, implement preventive controls and develop a written food safety plan to document the monitoring, correction and verification of their preventive controls.  This includes a documented recall plan.

Electronic record keeping will become paramount as the documents will need to be easily accessible for audits.  Paper records related to food safety and compliance are difficult to access when needed and can lead to outdated and incorrect information being presented to auditors. With the FSMA legislation many food manufacturers are re-examining this approach as the need to have a well-documented and easily updated product safety plan in place is fast approaching.  If you haven’t yet thought about what a very basic Product Recall Plan should include, you can download our 10 Essentials guide here . After reviewing our guide, if you have questions or need assistance in creating your Product Recall Plan, please let us know.

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Product Safety Planning and Social Media

In today’s ever evolving world of information sharing social media tools give consumers the ability to voice their opinions or vent frustration about a product or manufacturer. Unfortunately, these tools don’t provide easy ways to substantiate negative claims, and negative product comments can “go viral” in an alarmingly short time period. With big social media sites such as Facebook & Twitter a message post about a product can be around the world in a matter of minutes. How do manufacturers not only find out about these posts but quickly and accurately respond? The only way is through a well put together, documented and followed Product Safety Plan. Social media monitoring must be an integrated part of your Product Safety Plan. By monitoring social media outlets on a consistent basis you not only find out what your customers are saying about your products, you can determine if a defect exists that may require a recall of a product. Product Safety Planning is a proactive approach that requires the buy in and support of everyone in the company. With customer’s ever increasing desire for instant satisfaction, many manufacturers are now building social media teams that monitor and interact with their customers in the social media forums and report information to the product safety team on a daily basis. Has your company included social media as a part of your product safety plan? Do you need help in figuring out how to include it? Give us a call, we would be happy to speak with you.

Dan Hinkebein
Manager – Recall Business Services
Realtime Results

 

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What Does the New Food Safety Law (FSMA) Mean for You?

The Food Safety Modernization Act (FSMA) will change the way food manufacturers conduct audits and keep records. Here’s a quick look at some of the provisions in the new law:

• Issuing recalls: For the first time, FDA will have the authority to order a recall of food products. Up to now, with the exception of infant formula, the FDA has had to rely on food manufacturers and distributors to recall food voluntarily.
• Conducting inspections: The law calls for more frequent inspections and for those inspections to be based on risk. Foods and facilities that pose a greater risk to food safety will get the most attention
• Importing food: The law provides significant enhancements to FDA’s ability to oversee food produced in foreign countries and imported into the United States. Also, FDA has the authority to prevent a food from entering this country if the facility has refused U.S. inspection.
• Preventing problems: Food facilities must have a written plan that spells out the possible problems that could affect the safety of their products. The plan would outline steps that the facility would take to help prevent those problems from occurring.
• Focusing on science and risk: The law establishes science-based standards for the safe production and harvesting of fruits and vegetables. This is an important step forward. These standards will consider both natural and man-made risks to the safety of fresh produce.
• Respecting the role of small businesses and farms: The law also provides some flexibility, such as exemptions from the produce safety standards for small farms that sell directly to consumers at a roadside stand or farmer’s market as well as through a community supported agriculture program (CSA).

July 2012 is the government mandated deadline for all Food & Beverage manufacturers to have a documented product recall plan in place. If you are a Food/Beverage manufacturer and haven’t thought about what a very basic Product Recall Plan should include, you can download our 10 Essentials guide here  . After reviewing our guide, if you have questions or need assistance in creating your Product Recall Plan, please let us know.

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Get Our Guides to Recall Readiness Today

We’ve published two different publications that walk your organization through preparing for a recall. Check them out today.

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How do you measure the success of a Product Recall?

As a third party administrator of product recalls, one of the questions I’m most frequently asked is, “How do I determine if a recall is a success?” This is a very good question that unfortunately doesn’t have an easy answer. The simple answer would be to say a recall succeeds when 100% of the risk is eliminated. In reality, it is very rare to achieve 100% of anything let alone a product recall. There are too many factors to weigh to simply assign an arbitrary percentage and call a recall a success if it reaches that point. A more appropriate approach is to look at the recall campaign on a case by case basis. You need to try an answer a variety of questions such as:
[list-unordered]
How many customers have been notified directly?
How many attempts have been made to contact them?
What additional measures have been taken to notify customers?
What are the risk factors?
What is the product’s true lifespan?
How many reported incidents are there?
When was the last reported incident?
[/list]
The key is to identify and answer the questions that best relate to the needs and risks of your organization.

The most frequent follow-up question to the one regarding success is, “When can we end the recall?” The short answer to this question is eventually. Not exactly the answer most people desire. When someone says that a recall has been closed, what they are referring to is that the active reporting to the governing agency has ended. The governing agency still requires that the manufacture maintains the program and takes care of any customers that contact them regarding the recall. They also require the manufacturer to report any new incidents and they reserve the right to reopen the active reporting if they feel that it is needed.

Dan Hinkebein
Manager – Recall Business Services
Realtime Results

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North American Product Safety Agencies Team Up in the Name of Poison Prevention

As the United States marks the 50th anniversary of National Poison Prevention Week from March 18-24, the U.S. Consumer Product Safety Commission (CPSC) is teaming up with product safety counterparts in Canada and Mexico to call attention to the dangers of unintentional poisoning.

CPSC, Mexico’s Consumer Protection Federal Agency (Profeco), the Federal Commission for the Protection Against Sanitary Risks (Cofepris), and Health Canada have committed to working together to engage consumers during this week. Consumers need to know how to safely choose, use and dispose of potentially harmful products.

Unintentional poisoning is one of the leading causes of injury to children. Poisoning is a preventable injury. Yet each year thousands of children in the United States and across North America are treated in emergency departments after consuming poisonous substances.

“Fifty years of poison awareness efforts have resulted in thousands of lives saved,” said CPSC Chairman Inez Tenenbaum. “However, new and reemerging hazards, such as button cell batteries and chemicals that look like everyday drinks, have renewed CPSC’s efforts to raise awareness and encourage poison prevention.”

While child-resistant packaging, critical safety messaging and education efforts have contributed to a significant decline in deaths, the North American safety agencies are aiming to reduce even further the number of unintentional poisonings.

CPSC recommends that consumers layer the protection in three key steps:

1. Keep medicines and household chemicals in their original, child-resistant containers.
2. Store potentially hazardous substances up and out of a child’s sight and reach.
3. Keep the national Poison Help hotline number, 800-222-1222, handy in case of a poison emergency.

Additional poison prevention steps are:

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CPSC Adopts New Federal Standard for Portable Bed Rails

The U.S. Consumer Product Safety Commission (CPSC) voted (4-0) to adopt a new federal standard to make portable bed rails safer for children. A portable bed rail is used on the side of an adult bed to keep children, typically age 2 to 5 years old, from falling out of the bed.

The mandatory standard contains safety requirements for bed rails and addresses consumer assembly and installation problems that have resulted in child deaths. CPSC staff worked closely with the standards development organization ASTM International to update its consensus standard. CPSC’s new mandatory standard incorporates ASTM’s bed rail standard F2085-12.

The federal standard for portable bed rails includes the following requirements:

The improved warnings explicitly state that bed rails should never be used with children younger than two years old. They are intended for children age 2 to 5 who can get out of an adult bed without help. Gaps in and around bed rails have entrapped young children and killed infants.

The federal standard will go into effect six months after publication of the final rule in the Federal Register.

In addition to portable bed rails, the Commission has approved mandatory standards for other children’s products, including cribs, bath seats, baby walkers and toddler beds, as required by Congress in Section 104 of the Consumer Product Safety Improvement Act of 2008.

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Are You Prepared for A Recall?

Creating an effective Product recall management process that will protect both the consumer and company’s/brand’s reputation requires careful planning and active involvement of each involved department.  With changing regulatory environment, as a product safety professional, are you adequately equipped to handle a recall in your organization?  Are you familiar with the new technologies that help you monitor your supply chain? While preparing for a recall, it is critical to prepare yourself and your company about product safety and recall risks.

A third part recall specialist, who offer recall planning and consulting services, logistics services and turn-key solutions can help your company prepare for recalls and other product safety risks. When a product recall impacts your business, few companies are adequately prepared to navigate the regulatory complexities and the demands on internal resources. That’s where Realtime Results can help. Our years of expertise handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money.

Contact us today to know more about Realtime Results Product Recall Management Services.

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Building an Effective Product Recall Plan

A Product Recall Plan is more than a reactionary measure to a potential hazard. An effective Product Recall Plan will help you reduce your exposure when a potential hazard is discovered, reduce the cost associated with a recall, help reduce incidents and injuries to your customers, and can reduce the negative impact on your brand name if a recall is necessary.

A well written and documented Recall Plan is your GPS that guides you through an unfortunate situation and will help prevent wrong turns and getting lost in unknown territory. Like most things in life, a Recall Plan is not one size fits all. A generic Product Recall Plan will leave gaps that will increase your exposure when you find yourself in the midst of recalling a product. Your Product Recall Plan needs to be as unique as your business. It needs to take in account the structure of your business as well as the intricacies that set you apart from your competition. If you haven’t thought about what a very basic Product Recall Plan should include, you can download our 10 Essentials guide here  . After reviewing our guide, if you have questions or need assistance in creating your Product Recall Plan, please let me know.  I would be happy to help you.

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Is that really a playground?

A few months ago I was bicycling through my neighborhood and stopped for a breather at our neighborhood playground. It has been quite some time since I had actually look at the playground, but I was shocked to see that the big metal slide, monkey bars, merry-go-round and the spring horses were gone. Even the swing set was nowhere to be seen. Instead, there was a 10 foot by 20 foot play structure that included a 4 foot high plastic slide, a small walk bridge and 3-foot-by-3 foot platforms that connected the two and served as the steps to the slide. I wondered, what was behind the drastic change.

I decided to make an inquiry about the changes to our subdivision president. He told me that the board decided to make the playground safer for our children and reduce injuries by replacing the equipment with safer alternatives. I asked what types of injuries were being reported, to which he replied that as far as he knew, there had been no incidents on the playground. I then asked who or what playground safety guides they consulted to make their determinations. To this I was told that they didn’t consult anyone, and that they just used “common sense” to make the playground as safe as possible. Rather than getting into a debate about “common sense,” I simply thanked him for his time and went on.
With over a decade of product safety under my belt, I do agree many older playground installations are a potential safety risk. But playgrounds can be made safer and still maintain many of the traditional types of playground equipment. CPSC has published their Public Playground Safety Handbook which provides the specifics for creating and maintaining a safe playground for our kids without removing all of the equipment that challenges them and helps to build valuable skills. Current statistic show that there are over 200,000 playground related injuries treated in emergency rooms each year. By consulting the CPSC Public Playground Safety Handbook, we can achieve a balance between safety and a fun and challenging playground system.

As I pass the playground now, I have been making a conscious effort to look and see what type of use the new safe playground is getting. Over the few months, I have not seen anyone at the playground no matter when I go by. In the past, I can remember seeing kids there almost all the time and it didn’t matter how warm or cold it was. With a little more investigation we could have still had a playground the kids would enjoy and use.

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There’s a Recall App for that?

While searching for an app for my mobile device, I came across a website, www.apps.usa.gov.  My initial thought was I would find apps that would allow me to see what’s going on in congress.  My curiosity got to me so; I went to the site and was surprised to find about 100 apps.  These apps ranged from a 9/11 Memorial app, American Red Cross shelter locator app, an app for the CDC, apps for Military News, an app designed to help visually impaired determine the denomination of paper currency, etc.  As I scrolled down the page I found a Product Recall app.  This Product Recall app is linked to www.recalls.gov.  It allows users to see the current recalls as well as provides mobile access to the all of the recall information you can find through the www.recalls.gov website.  The app includes a search feature so that you can type in a product name to check for recalls and it also includes a barcode application that allows you to search by a products barcode.  Unfortunately for me the recall app is only available for Android but with Android powered smartphones accounting for almost 50% of the market, there are a lot of people who should have this app on their devices.

Dan Hinkebein, Product Recall Manager Realtime Results

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Product Recall Management – Are You Prepared For A Recall?

Risk Management is unfortunately an imperfect science. No matter how careful we are, even a probability of one in a million will, by definition occur on average one in a million times. It also seems that Murphy’s Law prevails because it is often our impression that these occurrences seem to ‘pick their moment’.
Like heart attacks, cancer, road accidents and muggings, product recalls happen to other organisations but could never happen to us! That is what everyone thinks until it does happen.

If it did happen to your organisation, could you cope? Would you know what to do? Could the company survive the cost let alone the bad publicity? Does your Risk Management policy include a Product Recall procedure?

During this tough time when a product recall impacts your business, few companies are sufficiently prepared to navigate the regulatory complexities and the demands on internal resources. That’s where Realtime Results can help. With years of expertise in handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money.

Contact us today to know more about Realtime Results Product Recall Management Services.

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HP Agrees to $425,000 Civil Penalty for Failure to Immediately Report Lithium-Ion Battery Packs

The U.S. Consumer Product Safety Commission (CPSC) announced today that Hewlett-Packard Company (HP), of Palo Alto, California, has agreed to pay a civil penalty of $425,000. The settlement agreement(pdf) has been provisionally accepted by the Commission (3-1).

The settlement resolves staff allegations that HP knowingly failed to report immediately to CPSC, as required by federal law, that certain lithium-ion battery packs contained a defect or created an unreasonable risk of serious injury or death. The lithium-ion battery packs can overheat, posing a fire and burn hazard to consumers. The packs were shipped with new HP Notebook computers, sold as accessories or provided as spare parts for various HP models.

CPSC staff alleges that by September 2007, HP knew of about 22 incidents associated with the lithium-ion battery packs. At least two of these incidents resulted in injuries to consumers. HP also was aware that at least one consumer apparently went to the hospital. HP did not receive any information on the consumer’s injuries or treatment, if any. CPSC staff also alleges that between March 2007 and April 2007, HP conducted a study, from which it obtained additional information about the lithium-ion battery packs.

HP did not notify the Commission about the incidents or the study until July 25, 2008. By that time, CPSC staff alleges that the firm was aware of at least 31 incidents involving the lithium-ion battery packs.

In October 2008, HP and CPSC announced a recall of about 32,000 lithium-ion battery packs. HP sold notebook computers for between $700 and $3,000 that contained the lithium-ion battery packs, as did computer and electronics stores nationwide and various Web retailers. Lithium-ion battery packs that were sold separately for use with the notebook computers retailed for between $100 and $160.

Federal law requires manufacturers, distributors, and retailers to report to CPSC immediately (within 24 hours) after obtaining information reasonably supporting the conclusion that a product contains a defect which could create a substantial product hazard, creates an unreasonable risk of serious injury or death, or fails to comply with any consumer product safety rule or any other rule, regulation, standard, or ban enforced by CPSC.

When a product recall impacts your business, few companies are adequately prepared to navigate the regulatory complexities and the demands on internal resources. That’s where Realtime Results can help. Our years of expertise handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money.

Contact us today to know more about Realtime Results Product Recall Management Services. To read more about this article, click here to go to CPSC website

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Proactive at the Ports: CPSC Stops Unsafe Products Before They Reach Consumers

Stepped up efforts by the U.S. Consumer Product Safety Commission (CPSC) to be more proactive have resulted in hundreds of millions of violative or dangerous units of products being stopped at U.S. ports and prevented from ever reaching the hands of consumers.

Working with U.S. Customs and Border Protection (CBP), CPSC staff screened thousands of consumer products that were either in violation of U.S. standards or otherwise unsafe and stopped them from ever reaching store shelves. The hard work of CPSC and CBP staff in 2010 and 2011 resulted in more than 6.5 million units of about 1,700 different children’s products being stopped at our nation’s ports, due to safety concerns or the failure to meet federal safety standards.

“Intercepting dangerous products as quickly and as early as possible, well before they make their way into the hands of children and other consumers, is consistent with our vision for CPSC to continue enhancing its protection of America’s families,” said Chairman Inez Tenenbaum.

The products stopped are wide-ranging. In addition to toys and other children’s products, items targeted at import include mattresses, art materials, household chemicals, lighters, fireworks, bike helmets and all-terrain vehicles. Some of the reasons they were stopped include violations of the standards for flammability, lead paint and lead content, phthalates and small parts.

Port surveillance is not new. Imported products have long been screened at the port by CPSC and CBP. However, since its creation in 2008, CPSC’s import surveillance and inspection team, has steadily increased the size of its staff at some of the largest U.S. ports of entry, at CPSC’s headquarters and at a CBP operations center.

“The marketplace of imported consumer goods has expanded rapidly in recent years requiring CPSC to take an increasingly global view of consumer product safety,” said Carol Cave, Director of the Office of Import Surveillance and Inspection.

“In response to the lead in paint recalls in 2007, CPSC started to place investigators at key ports of entry full time,” Cave added. “Having CPSC staff who have the training and equipment necessary to identify non-complying products under CPSC jurisdiction at the ports has improved coordination and cooperation with CBP and industry.”

According to Cave, working side by side at the ports has lead to more effective import enforcement by reducing exam times and increasing interagency communication. “We are working smarter,” adds Cave, “but, because of the large volume of products being imported that are under CPSC’s jurisdiction, it is critical that, as the agency moves forward, we systematically evaluate the risk of incoming shipments and expand the number of staff inspecting merchandise.”

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CPSC Reinforces Children’s Sleepwear and Loungewear Enforcement Policy to Apparel Industry

Agency standards designed to prevent burn injuries to children

In an effort to remind the industry of their obligations associated with children’s sleepwear and loungewear, the U.S. Consumer Product Safety Commission’s (CPSC’s) Director of Compliance and Field Operations sent a letter (pdf) to manufacturers, distributors, importers and retailers today reinforcing CPSC staff’s enforcement policy on children’s sleepwear and loungewear.

Highlights in the letter to industry review the definition of children’s sleepwear including loungewear as a type of children’s sleepwear. The Commission’s regulations define the term “children’s sleepwear” to include any product of wearing apparel (in sizes 0–14), such as nightgowns, pajamas, or similar or related items, such as robes, intended to be worn primarily for sleeping or activities related to sleeping. This definition exempts: (1) diapers and underwear; (2) “infant garments,” sized for a child nine months of age or younger; and (3) “tight-fitting garments” that meet specific maximum dimensions.

In the 1990s, a category of products called “loungewear” was introduced into the children’s market. CPSC staff views children’s “loungewear,” or other similar garments marketed as comfort wear, as garments worn primarily for sleep-related activities. Therefore, “loungewear” must comply with the children’s sleepwear standards.

The letter includes a summary of the Consumer Product Safety Improvement Act of 2008 (CPSIA) requirements for manufacturers and importers of children’s sleepwear sold online or in stores. These requirements include tracking labels, a certificate of compliance and testing requirements for phthalates, lead content and lead in surface coatings on snaps, zipper pulls and elsewhere on the product.

The children’s sleepwear standards were developed to prevent children’s sleepwear from igniting due to exposure to ignition sources, such as matches/lighters, candles, ranges, stoves, space heaters and fireplaces. Most of the ignition incidents occurred while children were wearing sleepwear or sleep-related items during the evening before bedtime or in the morning around breakfast time.

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Televisions are Hazardous

Growing up, our parents warned us that sitting to close to the TV was dangerous.  I doubt many of them were thinking the danger could be the TV falling on us, but while recently reviewing some statistic from the Consumer Product Safety Commission (CPSC), I saw that about 70% of children’s fatalities involve falling TV’s.

For those of us of a certain age, the TV’s our parents had when we were children were large heavy wooden consoles that sat on the floor.  The risk of them tipping over was slim.  As technology and styles changed TV’s no longer were built into the furniture but sat on top of it.  It was then that the risk of tip over began to increase.  They were heavy and often placed on furniture that was not intended to handle the bulk and weight of the television.  However, this type of television did have some counter weight on the back of it in the picture tube.  Now as we move to the next generation of televisions, Flat Panels, the risk of tip over has significantly increased again.

Flat panel TV’s weigh significantly less than the previous types but with the significant increase in risk of tip over they are still capable of seriously injuring or killing a small child if the child were to tip the TV onto them.  The typical 40 inch LCD TV weighs approximately 40 pounds.  A small child would not be able to get out from under the TV if they were to tip it over onto themselves.

Between the years 2000 and 2010, there were 176 child fatalities that involved a Television falling.  Between the years of 2008 and 2010, there were approximately 57,500 injuries treated in Emergency Rooms due to Televisions.

There are many ways to help reduce the risk of a TV tipping over.  They range from not placing things that would entice a child to climb on the TV to securing the TV to the furniture or wall.  As with the clasps we install on cabinet doors or the plastic plugs we place in outlets when child proofing our homes, a simple strap for your TV could save your child’s life.

A little preventative safety can go a long way.

 

Dan Hinkebein, Product Recall Manager Realtime Results

 

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Build-A-Bear Agrees to $600,000 Civil Penalty for Failing to Report Defective Toy Beach Chairs

The U.S. Consumer Product Safety Commission (CPSC) announced today that Build-A-Bear Workshop Inc. (Build-A-Bear), of St. Louis, has agreed to pay a civil penalty of $600,000. The penalty settlement agreement has been provisionally accepted by the Commission.

The settlement resolves CPSC staff allegations that Build-A-Bear failed to immediately report a defect involving its toy bear beach chair that resulted in incidents and injuries to consumers. The sharp edges of the chair’s folding wooden frame can pinch, lacerate or amputate a child’s fingertip if the finger is caught between the frame as the chair is folded.

Build-A-Bear sold the beach chairs through its website and at Build-A-Bear stores between March 2001 and October 2008. The company became aware of 10 reports of injury between July 2007 and January 2009, yet did not report to the Commission until March 2009.

Federal law requires manufacturers, distributors and retailers to report to CPSC within 24 hours after obtaining information reasonably supporting the conclusion that a product contains a defect, which could create a substantial product hazard, creates an unreasonable risk of serious injury or death, or fails to comply with any consumer product safety rule or any other rule, regulation, standard or ban enforced by CPSC. CPSC and Build-A-Bear announced a recall of about 260,000 beach chairs in May 2009.

When a product recall impacts your business, few companies are adequately prepared to navigate the regulatory complexities and the demands on internal resources. That’s where Realtime Results can help. Our years of expertise handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money.

Contact us today to know more about Realtime Results Product Recall Management Services. To read more about this article, click here to go to CPSC website

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Keeping the Holidays Safe

A Message from Recall Results

Now that the holiday season is in full swing, we should not let our guard down when it comes to safety. While we’re climbing on our roofs to hang decorations, plugging in multiple extension cords for the many strands of lights we’re stringing, decorating the real or artificial tree inside our homes, or considering the gifts that we give each other this time of the year, let’s remember to ensure our own safety and the safety of our loved ones.

Some Tips for Safe Holiday Lighting:

• Whether your lights are new or old, always look for the label from an independent 3^rd party testing lab.
• Check each string for broken, cracked, or loose sockets, bare or frayed wires, or loose connections. If you find a problem with a set, do not attempt to repair it yourself as there could be additional unseen damage.  Simply replace damaged sets.
• Read the instructions included with the lights. We all know how to plug cords in but, these instructions will tell also you the maximum number of sets you can plug together safely. Plugging too many sets together can cause the wire to overheat and present a risk of fire.

Some Tips for Quality, Safe Christmas Trees:

• If you choose a real tree, make sure the tree is fresh. A fresh tree should be nice and green. The needles are hard to pull out and should not break when you bend them. If you hold the tree and tap the bottom of the trunk on the ground, you should not see a lot of needles falling from it, as this would be a sign that the tree is too dry.
• Before placing the tree in your tree stand, cut about 2 inches of the trunk off.  This will allow the trunk to draw water from the stand easier and help extend the life of the tree.
•  Heated rooms can dry a tree out rapidly crating a fire hazard. Be sure to keep the stand filled with water checking it regularly. Placing the tree in an area away from heat sources will help, but will not eliminate all risk of the tree drying out.
• If you choose an artificial tree, make sure the tree you have chosen has a label that says it’s fire resistant.
• Do not use electric lights on a metallic artificial tree. Faulty lights could cause the tree to become electrically charged posing an electrocution risk to anyone touching it.
• For larger or unstable trees, it’s best to secure the tree to a wall or ceiling with guide wire to prevent it from toppling.

Reminders for Gift Buying

• If you are purchasing presents for children, be sure to look at the recommended age label to ensure the age appropriateness.
• When buying gifts, consider the safety of other children in the home. For instance, products that are designed for older children may have small detachable parts or strong magnets that could be harmful if swallowed by a small child. These parts become even more appealing to younger children when they see their older sibling playing with them.
• If you’re purchasing pre-owned products, a quick visit to www.saferproducts.gov can tell you if the product is affected by a recall.

Make it a safe and happy holiday season for all.

Dan Hinkebein, Product Recall Manager Realtime Results

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Toys Safer This Holiday Season Due to Stronger Safety Rules

It’s that time of year again, when parents, grandparents, and friends begin to prepare holiday toy shopping lists. The U.S. Consumer Product Safety Commission (CPSC) wants consumers to know that while safety should be at the top of everyone’s toy list, stronger federal rules are making a positive impact and restoring confidence in the safety of toys.
New toy safeguards include: establishing the lowest lead content and lead paint limits in the world; setting a stringent limit on the use of certain phthalates; converting the voluntary toy standards into mandatory standards; requiring third party testing and certification of toys designed or intended primarily for children 12 and younger; closing in on new limits for cadmium in toys; and working with the U.S. Department of Homeland Security to track shipments in transit from other countries, thereby increasing seizure of dangerous imported toys.
These safeguards, along with safety-conscious steps taken by many toy makers and sellers, have contributed to a continued decline in toy recalls since 2008. There were 34 toy recalls in fiscal year 2011. This is down from 46 toy recalls in fiscal year 2010, 50 recalls in 2009, and 172 recalls in 2008. In 2011, toy recalls related to lead declined to 4, down from 19 in 2008.
Toy-related deaths to children younger than 15 increased to 17 fatalities reported in 2010, up from 15 reported in 2009. Nearly half of these toy-related fatalities were attributed to choking on balloons, small balls, and rubber balls.

Here are some safety steps that consumers can take while shopping this holiday season:
• Balloons – Children can choke or suffocate on deflated or broken balloons. Keep deflated balloons away from children younger than 8 years old. Discard broken balloons at once.
• Small balls and other toys with small parts – For children younger than age 3, avoid toys with small parts, which can cause choking.
• Scooters and other riding toys – Riding toys, skateboards, and in-line skates go fast, and falls could be deadly. Helmets and safety gear should be worn properly at all times, and they should be sized to fit.
• Magnets – For children under age 6, avoid building or play sets with small magnets. If magnets or pieces with magnets are swallowed, serious injuries and/or death can occur.

Once the gifts are open:
• Immediately discard plastic wrappings or other packaging on toys before they become dangerous play things.
• Keep toys appropriate for older children away from younger siblings.
• Charging batteries should be supervised by adults. Chargers and adapters can pose thermal burn hazards to young children. Pay attention to instructions and warnings on battery chargers. Some chargers lack any mechanism to prevent overcharging.

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Is Your Recall Plan Ready?

In January of this year, President Obama signed the Food Safety Modernization Act in to law. As part of this act, food manufacturers and packagers are required to have a documented recall plan in place. The deadline on this portion of the act is July 2012. There are a lot of things to consider when you’re writing and documenting your plan. There are many facets and points of contact in manufacturing and even more that need to be considered and included in your recall plan. Key capabilities you will need to have in place include:
• The ability to track and trace your products
• The ability to track and trace your notices and responses to a recall
• A database capable of logging all recall instances that can be searched in an easy and efficient manner
When developing your plan, work to ensure that it can easily be accessed and understood by all levels of your business. Review the plan with each department so that everyone knows what is required of them if a recall is deemed necessary. At Realtime Results, we can help you to develop your recall plan and help you to avoid the risks of not having a proper plan in place.

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A Certification for Product Safety Management

I recently had the pleasure of being involved with St Louis University’s Center for Supply Chain Management Studies, Certification in Product Safety Management Course. Don Kornblet of ADK Information Services, LLC developed and supports this course to enhance the skills and knowledge of product safety managers.

The course provides instruction and overview of industry standards and procedures, and it allows students access and interaction with product safety industry leaders including the Consumer Product Safety Commission (CPSC). The most recent graduating class was comprised of students from a mix of manufacturing and retail companies with a common goal of gaining a better understanding of product safety practices. They are looking to take this information back to their organizations and use them to shape their companies product safety policies and bring product safety to the next level. The group was very open with sharing their experiences and accepting feedback and suggestions not only from the instructors and speakers but from each other.

The course created a great deal of exchange and new relationships were created that I believe the students can build on in the future to continue the advancement of product safety. The course is truly helping to advance product safety knowledge. I would like to commend the students, St Louis University and Don on a job well done.

By Dan Hinkebein, Product Recall Manager Realtime Results

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CPSC Launches Online Reporting Tool for Businesses

Changes Are Part of CPSC’s Information Technology Modernization Effort

The U. S. Consumer Product Safety Commission (CPSC) has launched important new features to the SaferProducts.gov Business Portal that make it easier and more efficient for businesses to work with CPSC. These changes are a key part of the agency’s overall information technology modernization effort.

A new, comprehensive online form allows manufacturers, private labelers and importers to quickly submit required reports of potentially hazardous or defective products to CPSC. The online form makes it easier for businesses to report product hazards and to communicate information on consumer product safety issues with CPSC.

Another improvement expands CPSC’s ability to correspond with all of the businesses registered on SaferProducts.gov using the Business Portal, instead of postal mail. All registered manufacturers, importers and private labelers identified in incident reports will now receive notices electronically, regardless of whether the report is eligible to be published on SaferProducts.gov. Previously, businesses could only receive SaferProducts-eligible reports electronically. This new feature is an example of efficiencies and cost savings being achieved through our information technology overhaul.

With this release, the structure has been put in place to eventually allow businesses registered in the Business Portal to add brand names for products they sell or have sold. Along with brand names, the time periods during which the company sold each brand also can be identified. This information will help CPSC more easily contact the appropriate business when a report about a product is submitted to SaferProducts.gov.

These enhancements to the SaferProducts.gov Business Portal are largely a response to requests and feedback CPSC received from businesses and trade associations.

SaferProducts.gov was launched on March 11, 2011, allowing consumers to report and search for reports of harm or risks of harm. As of the October 31, the site contains more than 4,100 consumer product-related reports.

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When it Comes to Product Recall Planning – There’s No Time Like the Present

It may shock you but, the best time to develop a product recall plan is at the outset of your products lifecycle –during the product development stage. During product development, you should be thinking about how to incorporate identifiers into your product where they are easily accessible to your customers. This will not only save you time if a recall is necessary but will also save you money.

With some early planning, you can greatly simplify the process if your product faces a recall. Planning to have identifiers such as model numbers, date codes and batch codes prominently displayed on the product, gives you a way for your customers to quickly self-identify if their product is affected. Having customers provide this information back to you also helps to determine the potential scope of a recall. For example, you discover that a screw is coming loose in your product presenting a safety issue. During peak production, you manufactured this product on four lines. By checking the date codes and batch numbers provided by customers who report a program, you are able to review the logs and determine the problem was due to a calibration error on a single line. Since you have all of this data logged and the products are clearly marked, you can narrow the scope of the recall to only those items manufactured during that time period on that particular line. You have just reduced your total affected products for this recall and the cost associated by three fourths. While this may be an overly simplified example, it clearly demonstrates how taking a few simple steps up front can save you time and money down the road.

If you are looking for insights for proactive planning for recalls, contact Realtime Results. With over a decade of experience in managing product recalls, we can help you understand what you need to have in place to make the unpleasant situation of recalling a product a little more bearable.

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Delaying a Product Recall – The Risks Outweigh the Rewards

Product recalls are challenging and definitely something an organization would prefer to avoicd. But when you face a recall, timing is of the essence. In order to reduce risk to your customers, and to your business, you must act quickly and efficiently.

When an organization identifies a potential safety issue with one of their products, often times the initial reaction is negative due to concerns regarding cost and the financial impact. The organization may be resistant, and there are costs to bear. At minimum, you’ll face expense for providing a retrofit or replacement part to all of your affected customers. In addition, you will have the cost of production, shipping, tracking, and ensuring completion from your customers. But regardless of the timing of your product recall, these costs are a given. Delaying the process can amplify your organization’s expenses.

Once you determine that a safety issue exists, it is inevitable that a recall will have to be carried out. You’re company has two options. You can put together a report and file a fast track recall plan with the CPSC, or you can wait for the CPSC to identify the issue from your customers through the saferproducts.gov website. If you choose to wait for the CPSC to come to you, you face additional risk and possible expense due to the potential for additional injury claims and consumer lawsuits. The CPSC also can assess civil penalties for failure to report a known defect in a timely manner. By waiting, the financial impact to your company can far exceed the costs if you quickly address the recall. By waiting, you also raise the risk of creating significant damage to your company’s brand and reputation.

The clearest course of action is to act quickly. You reduce your exposure, keep your customers safe and reduce the financial expense. Call us today if you are questioning the best path forward. We are ready to help.

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CPSC Adopts Independent Third Party Testing and Certification Rules for Children’s Products

Rules ensure continued compliance with child safety requirements

The U.S. Consumer Product Safety Commission (CPSC) has voted to approve (3-2) new independent third party product testing rules for domestic manufacturers, importers and private labelers. These firms will be required to test and certify that their children’s products comply with U.S. product safety standards as required by the Consumer Product Safety Improvement Act of 2008. In order to meet this requirement for children’s products, the Commission adopted a framework regarding third party periodic testing to ensure continued compliance.

If there is a material change to the product, such as changes in the product design, manufacturing process, or the source of component parts, firms must re-test and and re-certify that the product complies with federal safety standards.

In addition, firms must keep records on the testing and certification for their children’s products. The testing and certification rule will go into effect 15 months after it is published in the Federal Register.

Children’s products that comply with the law may bear the label, “Meets CPSC Safety Requirements.” Labeling is voluntary.

In an effort to reduce the burden on all affected firms, the U.S Consumer Product Safety Commission also voted to approve (3-2) a rule allowing firms to use component part and finished product testing conducted by their suppliers, in order to meet the testing and certification requirements, effective 30 days after the rule is published.

Firms are already required to do intial testing on some products, including among others, those with lead in the paint, those with small parts, full size and non-full size cribs, pacifiers and children’s metal jewelry. The new rules will require firms to go beyond initial testing to ensure that their products continue to meet safety standards. All domestic manufactures, importers and private labelers of children’s products will be required to test the products periodically to ensure continued compliance with federal safety standards.

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Were the good old days really so good?

We all enjoy reminiscing about the good old days of our youth. My brothers and I enjoyed any and all
types of sports. Sun up to sun down we were outside riding bikes, playing ball, and generally being free
of adult supervision doing all of the things we would cringe if we found our children doing today. After
watching the Eastern Europeans dominate the Shot put in the 1976 Olympics, our father made us Shot
puts out of lead. Yes, we were playing with lead that my father melted down and cast into round balls
throwing them time and time again across the yard. Holding them to the sides of our necks and faces
mimicking the Olympians we had just watched. No one gave any thought to this even after the CPSC
issued the initial ban on lead based paint only a year later in 1977. How many of our generation helped
slather that nice lead-based paint throughout our homes? What about Mercury? We all remember the
Mercury filled fever thermometers, which were not banned until 2002. But, what about the bottles of
Mercury we used in science labs? I remember rolling balls of Mercury around in our hands or flicking
them back and forth across the lab tables. Yes we were warned to minimize or avoid exposure to our
skin but as teenagers we did not listen or even fathom that there could be anything wrong with this.
Years later we found out that the mere one gram of mercury contained in a thermometer was enough
to contaminate all of the fish in a 20 acre lake.

With many mandatory and voluntary regulations governing the products sold as well as consumers
being more environmentally responsible when disposing of older no longer used products, we as a
society are working diligently to reduce exposure to these types of products.

Dan Hinkebein – Product Recall Manager

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Pay Due Attention To Recall Notices

Are we becoming too safe as a society?  In today’s world safety is paramount.  Everyday items contain multiple safety features and warnings.  My cup of coffee comes with a warning proclaiming that it’s hot.  My hair dryer advises me not to use it in the tub.  Bottles of hand sanitizer can be found all over our office.  With this in mind, has the overload of warnings kept us safe or have they caused us to turn a deaf ear?  An old joke comes to mind of a guy who goes to the doctor and says, “Doc, it hurts when I do this.” The doctor replies, “Then don’t do that”.  Now we’re told, “don’t do that” before the thought even crosses our mind.

We’re warned so often and in so many ways, but do we actually pay attention to the more critical warnings such as recall alerts?  After working as a third party administrator of recalls for 13 years, I recently caught myself not listening.  I received a notice about a recall on our SUV.  I filed the letter in my To-do box and didn’t give it much thought until about 2 months later when the failure described in the notice happened while driving to work.  I knew the service manager at the dealership fairly well and he knew what I do for a living.  So, the first question he asked me was “how did you of all people not know about this?”  Sheepishly I told him I not only received the notice but, I knew the recall was going to be happening about a month prior to the letter being sent.  This got me thinking, if I’m not taking prompt action from a recall notice I receive how can I expect the typical consumer to do so?  There have been a lot of changes in the way we notify consumers of recalls in the last 13 years.  We now issue press releases, send letters, launch websites, put posters in retail stores, send notices in utility bills, etc.  You can enter any product name in an internet search engine and if there has been a recall, you will get several web pages that have that information posted on them. Even with all of this availability of information, we still have not seen a significant increase in the completion percentages of a typical recall.

Dan Hinkebein
Manager, Recall Business Services

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Overcome The Communication Challenges During A Product Recall Event

During any serious product recall event, there are mainly 3 specific tactical communication concerns:

1. How to get the message out to the targeted audience that has to take action to remove the recalled product or other actions as quickly as possible?
2. How to track the responses from the targeted audience (for example, direct customers, store managers), including not only acknowledgement of the response but compliance to the directions?
3. How do we maintain an on-going emergency dialogue (outstanding issues, new information) that doesn’t get lost in the day-to-day volumes of email and voicemail?

During a product recall event, the key to maintaining a positive relationship with consumers and regulators is transparent communication. However, those transparent communications efforts are of no good if they are not supported by quick and effective recall management, a process that can be streamlined and expedited by partnering with experts who have been in the recall management business before.

Realtime Results provides comprehensive product recall services and product recall management. Our years of expertise in handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money. Contact us today to know more about Realtime Results Product Recall Management Services.

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Even With a Focus on Product Safety – Product Recalls Still Happen

Consumers have a long standing misconception regarding product manufacturers.

Being a third party administrator for product safety recalls puts me in a unique position. In conversations, when I tell people what I do, one of the responses I receive most often is, “If only manufacturers didn’t look for the cheapest way to make products with no concern for safety, they wouldn’t have these problems.” This public perception is the complete opposite of reality. In almost every recall I have worked on in my 13 year in this industry, manufacturers do their best to produce a quality product that is safe for their consumers.

The vast majority of products goes through extensive testing both internally and externally before and after mass production of the product has begun. If a safety issue arises, it is frequently because of an unforeseen issue that is found after a product has been in use. Sometimes the issue is found to be caused by a product being used in a way that neither the manufacturer nor the outside testing labs had foreseen. Most product recalls today are done on a voluntary basis. The manufacture discovers a potential safety issue and contacts the governing agency(s) to issue a recall of the product. Unfortunately, most people carry an erroneous perception that manufacturers are more concerned with profit than with safety. It seems people don’t notice the statement on the top of a recall press release that says “in voluntary cooperation . . .”

At Realtime Results, we are lucky to work closely with high-quality manufacturers who need help when something goes wrong despite their best efforts. At Realtime, we will continue to manage recalls efficiently using methods refined through our extensive experience.

Dan Hinkebein
Manager, Recall Business Services

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CPSC Warns of Drowning Dangers in Bathtubs, Bath Seats and Buckets

The danger of drowning for young children is a real one, all year long. Drowning is the leading cause of unintentional death among children ages 1 to 4. With Labor Day representing the traditional end of the pool season, parents and caregivers need to know that drowning risks inside the home are ever present.

In fact, bathtubs are the second leading location, after pools, where young children drown. Buckets, other containers, and even landscaping features, also can present a danger of drowning.

A new report from CPSC on submersions related to non-pool and non-spa products indicates that from 2005 to 2009, there were 660 submersion incidents involving children younger than five years old. There were 431 fatalities, 212 injuries and 17 incidents with unknown injuries. The majority of the victims were younger than the age of two and most of the incidents involved bath or bath related products. CPSC’s analysis of the fatalities found that 92 percent occurred in residential settings.

“Young children can drown in just a few inches of water,” said Chairman Inez Tenenbaum. “I urge parents and caregivers to constantly supervise young children around bathtubs, bath seats and buckets. There are simple steps that every family can take to prevent drownings in the home.”

Many of the reported incidents involved a lapse in supervision, such as a parent or caregiver leaving the bathroom while the child was in the bathtub to answer the phone or door, or to retrieve a towel. In other incidents, an older sibling was left to watch a younger sibling.

CPSC’s drowning prevention safety tips include:

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CPSC and USFA Warn About Deadly Dangers That Can Linger After Hurricane Irene Passes

Survival Tips After a Hurricane Strikes

The U.S. Consumer Product Safety Commission (CPSC) and U.S. Fire Administration (USFA) are warning residents in hurricane-impacted areas about the deadly dangers that can remain even after Hurricane Irene strikes.

Consumers need to be especially careful during a loss of electrical power, as the risk of carbon monoxide poisoning and fire increases at that time.

In order to power lights, to keep food cold or to cook, consumers often use gas-powered generators. CPSC and USFA warn consumers NEVER to use portable generators indoors or in garages, basements or sheds. The exhaust from generators contains high levels of carbon monoxide (CO) that can quickly incapacitate and kill.

From 1999-2010, nearly 600 generator-related CO deaths have been reported to CPSC. CPSC is aware of an annual average of 81 deaths due to carbon monoxide poisoning from generators in recent years. The majority of the deaths occurred as a result of using a generator inside a home’s living space, in the basement or in the garage.

Do not put your family at risk. Follow these important safety tips from CPSC and USFA in the aftermath of a storm.

Portable Generators

Never use a generator inside a home, basement, shed or garage even if doors and windows are open. Keep generators outside and far away from windows, doors and vents. Read both the label on your generator and the owner’s manual and follow the instructions. Any electrical cables you use with the generator should be free of damage and suitable for outdoor use.

Charcoal Grills and Camp Stoves

Never use charcoal grills or camp stoves indoors. Burning charcoal or a camp stove in an enclosed space can produce lethal levels of carbon monoxide. There were at least seven CO-related deaths from charcoal or charcoal grills in 2007.

CO Alarms

Install carbon monoxide alarms immediately outside each sleeping area and on every level of the home to protect against CO poisoning. Change the alarms’ batteries every year.

Electrical and Gas Safety

Stay away from any downed wires, including cable TV feeds. They may be live with deadly voltage. If you are standing in water, do not handle or operate electrical appliances. Electrical components, including circuit breakers, wiring in the walls and outlets that have been under water should not be turned on. They should be replaced unless properly inspected and tested by a qualified electrician.

Natural gas or propane valves that have been under water should be replaced. Smell and listen for leaky gas connections. If you believe there is a gas leak, immediately leave the house and leave the door(s) open. Never strike a match. Any size flame can spark an explosion. Before turning the gas back on, have the gas system checked by a professional.

Candles

Use caution with candles. If possible, use flashlights instead. If you must use candles, do not burn them on or near anything that can catch fire. Never leave burning candles unattended. Extinguish candles when you leave the room.

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With So Many Product Safety Rules, What’s a Manufacturer to Do?

Since the early 1970s, the US has had the Consumer Product Safety Commission (CPSC) monitoring products and creating new product safety regulations. The agency, congress and manufacturers have been working together over the last 40 years to build safer products and to help protect consumers and children from potentially harmful products and substances.

As the economy becomes ever more global, governments of other countries are beginning to feel the pressure from consumers and consumer groups to beef up their own product safety. Recently, Canada enacted it’s Consumer Product Safety Act which, for the first time in history, empowers Health Canada to order recalls and corrective action measures. The debates regarding heavy metals and phthalates that have been going on in the US for several years, are now taking place in Europe. Rising concerns from consumers in India are surfacing in the media questioning their government as to when their citizens will be afforded the same piece of mind consumers in other countries have. Regulations and requirements can vary greatly from one country to another.  With manufacturers depending on global sales to sustain their companies, maintaining up to date knowledge of regulations in the multiple areas you sell products is no longer a single person part time job.

Manufactures who wish to continue to grow globally are building product safety and compliancy teams just to keep a handle on the constantly evolving processes and regulations. This typically can leave a manufacturer shorthanded if a situation arises that requires a product to be recalled. This is where partnering with a company with a wealth of experience in managing product recalls can be a welcome resource. Don’t let panic set in. By having a recall partner as part of your overall product safety plan, your company will have expertise they can rely on. Realtime Results product recall division provides this type of support and assistance to companies every day.

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CPSC Renews MOU With Brazilian Government to Improve Product Safety

The U.S. Consumer Product Safety Commission (CPSC) renewed a memorandum of understanding (MOU) with Brazil`s National Institute of Metrology-Standardization and Industrial Quality (Inmetro), to improve product safety.

The two agencies have agreed on a plan of work with joint activities designed to foster cooperation to promote consumer product safety in both countries. The signing ceremony took place at Inmetro’s Laboratory Campus in Xerém, Rio de Janeiro.

In addition to enhancing information sharing, CPSC and Inmetro will work collaboratively to align product safety requirements whenever possible. A first step in this initiative is to consider the possibility of aligning crib safety requirements. Inmetro intends to work closely with the CPSC to evaluate samples according to the requirements defined in U.S. and Brazilian regulations.

“Brazil continues to be an important partner as we work to ensure safer products,” stated Chairman Tenenbaum. “We will share expertise and experiences and expand the flow of information and activities. Together, we will look for the highest levels of safety; we will be proactive, rather than reactive; and we will operate with a renewed focus on injury prevention.”

With safety standards & regulations getting tough day by day, is your organization well prepared in case of any untoward incident? Contact us today to get an expert opinion & consultation on your organization`s readiness to handle a product recall.

Don`t forget to check our expert report on 10 Essentials For Managing a Product Recall.

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Stay on the Change to 100ppm Lead Limit For Bicycles

This week without much fanfare congress passed CPSIA Amendment, HR-2715 just prior to adjourning for vacation.  The bill provides a stay on the change to 100ppm lead limit for Bicycles, Youth ATV’s.  The stay, however, does not include plastic parts on these items.  So, any plastics used on bicycles or youth ATV’s must still comply on August 15^th with the 100ppm regulation.  In addition, the bill allows added language to clear up the confusion on resale of used children’s products.  There are some restrictions set forth on used children’s product sales.  The bill first defines a “used children’s products” as a product that was obtained by the seller for use and not for the purpose of resale or was obtained by the seller, either directly or indirectly, from a person who obtained such children’s product for use and not for the purpose of resale.  The terms however do not apply to children’s metal jeweler, any children’s product the donating party or the seller has knowledge that is in violation of the lead limits or any children’s product or product category that the commission determines are in violation.

The bill also states that CPSC may make and implement special rules and consideration for small batch manufacturers.  This is intended to help ease the burden of testing cost for the smaller manufacturers.  The bill defines a small batch manufacturer as a manufacturer that has no more than $1,000,000 in total gross revenue from sale of all consumer products in the previous calendar year.

 

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CPSC Adopts Testing Requirements for Phthalates in Children’s Toys and Child Care Articles

The U.S. Consumer Product Safety Commission (CPSC) to approve new third party testing requirements for phthalates, through a notice of requirements, to ensure that children’s toys and child care articles meet the federal phthalates limits.

Phthalates are a type of chemical used to make plastics and other materials more flexible. The Consumer Product Safety Improvement Act of 2008 (CPSIA) permanently banned the use of three phthalates in concentrations greater than 0.1 percent in children’s toys and child care articles and temporarily banned the use of three others in concentrations greater than 0.1 percent in children’s toys and child care articles that can be mouthed, sucked or chewed pending further study. Since February 2009, it has been unlawful to manufacture or import children’s toys and child care articles violating these standards.

The CPSIA also required testing to prove compliance with these standards. While makers and sellers of toys and child care articles have had to comply with the phthalates requirements for more than two years, the Commission has voted previously to give manufacturers, importers and private labelers additional time to put a third party testing program into place. CPSC has approved a stay of enforcement on the requirement for third party testing and certification of these children’s toys and child care articles to the phthalates limits until December 31, 2011. The Commission will enforce certification of compliance with the phthalates limits based on third party testing of children’s toys and child care articles manufactured or imported after that date.

The Commission agreed with the staff’s recommendation that only those plastic parts or other product parts which could conceivably contain phthalates should be tested. Untreated/unfinished wood, metal, natural fibers, natural latex and mineral products are not expected to inherently contain phthalates and need not be tested or certified provided that these materials have neither been treated or adulterated with the addition of materials that could result in the addition of phthalates into the product or material. The guidance contained in the Commission’s August 2009 Statement of Policy for certain other materials, such as polyolefins, remains in effect.

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Safer Cribs for Babies Available – Retailers required to sell only cribs that meet CPSC’s new crib standards

June 28, 2011 marks the day when consumers started seeing a new generation of safer cribs for sale at local and national retail stores. Safer cribs mean a safer sleep for babies across the country. On December 15, 2010, the U.S. Consumer Product Safety Commission (CPSC) voted unanimously to approve new mandatory crib standards, establishing the most stringent crib safety standards in the world. Starting today, all importers, distributors, manufacturers, and retailers must offer only cribs that meet the CPSC’s new and improved full-size and non-full-size crib standards.

A safe crib is the safest place for a baby to sleep. It is for this reason that I am so pleased that parents, grandparents and caregivers now can shop with confidence and purchase cribs that meet the most stringent crib standards in the world,” said Chairman Inez Tenenbaum. “From the start, our goal has been to prevent deaths and injuries to babies in cribs, and now the day has come where only stronger and safer cribs are available for consumers to purchase.”

CPSC has recalled more than 11 million dangerous cribs since 2007. Drop-side cribs with detaching side rails were associated with at least 32 infant suffocation and strangulation deaths since 2000. Additional deaths have occurred due to faulty or defective crib hardware. The new standards aim to prevent these tragedies and keep children safer in their cribs.

Starting on December 28, 2012, child care facilities, including family child care homes and infant Head Start centers, as well as places of public accommodation, such as hotels and motels, and rental companies must use only cribs that comply with the new crib standards.

The Consumer Product Safety Improvement Act of 2008 (CPSIA) required the CPSC to update the old crib standards, which had not gone through a major revision in more than 30 years, to ensure that the standards provided the highest level of safety possible.

For more information on crib safety and the most up-to-date information on how to create a safe sleep environment for your baby, visit CPSC’s crib information center at: www.cpsc.gov/cribs

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CPSC Lowers Limit for Lead Content in Children’s Products

Consumer product manufacturers take note. The U.S. Consumer Product Safety Commission (CPSC) voted (3-2) that there was insufficient evidence to make a determination that manufacturers of children’s products sold in the United States could not meet a total lead content limit of 100 parts per million (ppm) for a product or product category. The new total lead content limit, which is called for in the Consumer Product Safety Improvement Act (CPSIA), goes into effect on August 14, 2011 for manufacturers, importers, retailers and distributors of children’s products.

Through the CPSIA, Congress set tough new levels for lead content in products designed or primarily intended for children 12 and younger. Lead is a heavy metal that is toxic for children, and associated with lowered levels of learning, impaired hearing, brain damage and, at high levels, can be fatal.

Congress directed CPSC to phase in the reduced levels for lead content over a three year period, starting with 600 ppm on February 10, 2009. The level dropped to 300 ppm on August 14, 2009. Finally, Congress directed the total lead content limit be set at 100 ppm, unless the Commission determined it was not technologically feasible for a product or product category.

The Commission was not able to determine that 100 ppm total lead content is not technologically feasible, as staff found that materials containing less than 100 ppm total lead content are commercially available in the marketplace for manufacturers. CPSC staff also found many products currently on the market, that have been tested by CPSC or other organizations, that are already in compliance with the new 100 ppm total lead content limit.

Starting on August 14, 2011, manufacturers, importers, retailers and distributors of children’s products must comply with the new 100 ppm federal limit for total lead content. CPSC will not enforce the CPSIA’s independent third party testing requirement for total lead content until December 31, 2011, due to a stay of enforcement that is already in place.

The stay of enforcement does not apply to children’s metal jewelry, which currently must undergo independent third party testing.

The new 100 ppm lead content limit does not apply to inaccessible (internal) parts of children’s products and certain component parts of children’s electronic devices, like electronic connectors and plugs, including headphone plugs.

Lead content levels for children’s products are different from the levels Congress set for lead in paint or surface coatings. The limit for lead in paint or surface coatings is .009 percent. The .009 percent level has been in place since August 14, 2009 and independent third party testing is required for all paints or surfaces coatings used on children’s products.

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Product Recall Management and Social Media

Have you ever stopped to think about the importance of social media in your recall communication? Just a few short years ago, social media didn’t even exist and yet today we could not see ourselves without it. With more than 500 million active users, today’s social media landscape is a critical communication vehicle for consumers.

Recent research conducted by the Pew Research Center shows that only about one-in-four (26%) Americans say they read a newspaper in print, down from 30% two years ago and 38% in 2006. Considering these numbers, one cannot afford to miss half of the audience you need to reach by using only traditional media for your product recall communication.

By including social networks such as Facebook and Twitter consumer oriented Blogs to your recall communication effort, you can supplement traditional recall notification, improve recall effectiveness and customer outreach, and demonstrate the effectiveness of your recall management. A recall management service such as the one offered by Realtime Results can help you to come up with a thorough, multidimensional online and social media strategy that is ready to be deployed with all other elements of the recall process.

Realtime Results provides comprehensive product recall services and product recall management through its Recall Results division. Our years of expertise in handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money. Contact us today to learn more about Realtime Results Product Recall Management Services.

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Canada Consumer Product Safety Act (CCPSA) Made Official

For our partners and companies who distribute products in Canada, please note that the Canada Consumer Product Safety Act (CCPSA) went into effect on June 20, 2011. Along with the act, Health Canada has released a Mandatory Incident Reporting (MIR) guide. The Guide may be found through this link, http://www.hc-sc.gc.ca/cps-spc/pubs/indust/2011ccpsa_incident-lcspc/index-eng.php

Per section 5 of the MIR, Determination of an “incident”, the CCPSA required a person to determine whether an event is “related” to a consumer product that they manufacture, import, or sell in Canada for commercial purposes and that the event meets one of the criteria set out in paragraphs 14(1)(a) through (d).

The following questions can assist in the determination of whether an event is a reportable incident:

• Does the event relate to a consumer product that I sell, manufacture or import in Canada for commercial purposes (including its components, parts or accessories or packaging)?
• Does it meet the criteria of an incident in either one of paragraphs 14(1) (a) through (d)?
• Does it indicate an unreasonable hazard posed by the normal or foreseeable use of the product or the foreseeable misuse of the product?

Upon consideration of these questions, a person may then have information from which one may reasonably conclude that the event is a reportable incident.  This constitutes awareness of an incident.

It is only once a person has completed this determination and become “aware” of an incident that the 2 and 10 day timelines specified in the CCPSA commence.

 

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Consumer Product Safety Commission (CPSC) Opens New Product Testing and Evaluation Center.

The Consumer Product Safety Commission (CPSC) recently announced the grand opening of a New State-of-the-Art National Product Testing and Evaluation Center. This center will enhance CPSC’s ability to protect families and consumers from harm by expanding CPSC’s testing capabilities, increasing the efficiency of agency staff and equipment, and allowing more testing to be done faster.”With the CPSC ramping up its testing efforts, manufacturers and retailers must be more vigilant in their recall planning and recall management efforts.

The new center has 63,000 sq. ft. of office and lab space. Lab space has increased nearly 250 percent – from just 13,000 sq. ft. at the former lab – to 32,000 sq. ft. in the new center. New equipment and improved testing chambers will allow the agency to complete more in-house testing than previously possible. The center has got nine labs for the specialized testing of goods, including children’s toys and electronics among a wide range of other consumer products.

Seventy-five agency scientists and engineers will now work together at CPSC’s new National Product Testing and Evaluation Center. CPSC claims that its new center will help in saving taxpayer`s money by allowing it to use fewer outside sub-contractors for its product tests. The new center`s testing abilities will help in preventing customers from buying and using unsafe products.

At the center’s grand opening, Senator Dick Durbin (D-IL), who helped secure funding for the new facility, said that “this state-of-the-art testing facility marks the next step in our efforts to rebuild CPSC into our premier watchdog agency. America’s families can sleep better at night knowing that the consumer-safety cops are on the beat and in the lab.”

The new CPSC center is the latest signal that the consumer safety agency is actively working to meet the oversight needs of an increasingly fast-paced global marketplace. “Today’s opening marks a new day in consumer safety,” said CPSC Chairman Inez M. Tenenbaum. “This center will enhance CPSC’s ability to protect families and consumers from harm by expanding CPSC’s testing capabilities, increasing the efficiency of agency staff and equipment, and allowing more testing to be done faster.”  As the agency gets settled in to its new facilities, manufacturers should make sure that they are meeting safety compliance standards and are prepared to manage a recall should one ever be necessary.

Realtime Results provides comprehensive product recall services and product recall management. Our years of expertise in handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money. Contact us today to know more about Realtime Results Product Recall Management Services.

 

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A Solid Corrective Action Program is a Plan for Success

Preplanning for a Corrective Action Program can save a company a lot of time and headache. By putting together a Corrective Action Plan which includes all of the key resources and defines the roles in a Corrective Action Program, you can ensure that all of your bases are covered in the event you find yourself faced with a Product Recall.

A key element is conducting periodic mock recall drills where you internally activate a Corrective Action Program and ensure that your company’s Corrective Action Plan is followed. This will help each department become more comfortable in the event that a real Corrective Action Program needs to be implemented. This simple exercise can help you identify gaps in your company’s Corrective Action Plan or with your individual type of Corrective Action Program. For you mock drills, you should use varying situations that relate to real world possibilities for your products. If you only use a single type of situation for your mock Corrective Action Program, you will not be able to effectively identify potential oversights within a Corrective Action Program.

Author:
Dan Hinkebein
Manager, Recall Business Services
Realtime Results

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Effective Product Recall Management – A Step towards Protecting Company`s Reputation

Creating an effective Product recall management process that will protect both the consumer and company’s/brand’s reputation requires careful planning and active involvement of each involved department.

A third party Recall Services provider can help you  to develop an effective product recall management/recovery plan; help you understand product recovery vs. product recall and its classification and provide examples of recent product recalls. Another crucial element in the product recall management program is communication with the public as well as customers, employees and share holders. The company must be prepared to respond effectively and consistently.

How well your company manages the crisis situations it will make a significant difference in how your company brand is perceived in the public’s eyes and how well it succeeds in today’s highly competitive marketplace. In current economic situation, most of the time product recalls are almost impossible to prevent at all time.  However having an effective product recall management program, at least your team can manage the crisis situation appropriately with necessary response actions, protect the health and safety of your customers, comply with regulatory requirements/laws and protect the image and reputation of the company and its products.

When a product recall impacts your business, few companies are adequately prepared to navigate the regulatory complexities and the demands on internal resources. That’s where Realtime Results can help. Our years of expertise handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money.

Contact us today to know more about Realtime Results Product Recall Management Services.

 

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Realtime Results Sponsors Scholarship for St. Louis University Product Safety Management Course

St. Louis, MO – June 6, 2011 – Realtime Results, a St. Louis-based provider of product recall consulting and services, is playing an active role in St. Louis University’s innovative Product Safety Management course. The course, designed for product safety managers, is the only certified education program for product safety management in the world. Realtime Results is participating both as a presenter for the course and by sponsoring a scholarship to one of the programs students.
“Realtime Results is a leader in providing outsourced product recall support and consulting,” explains Dan Hinkebein, manager of Realtime Result’s Product Recall Business Services division. “St. Louis University in cooperation with ADK Information Services is taking the lead in helping to define a curriculum and a certification program that will help companies deal with the regulatory challenges and the ever-changing landscape of product safety issues.”
Hinkebein will be one of the spotlighted speakers for the program covering information on managing product recalls. Mr. Hinkebein is a recognized leader in the industry and has an extensive background with managing product recall actions.
In addition to Mr. Hinkebein’s participation, Realtime Results has provided a scholarship to one of this year’s attendees. The company is sponsoring Amy Lane, Manger of Global Compliance Testing from Sportcraft. “We are dedicated to helping companies better manager product safety related issues,” Hinkebein says. “By helping to sponsor attendees, we are working to grow product safety knowledge and hopefully showing our commitment.”
Classes for St. Louis University’s Product Safety Management course begin June 6.

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Product Recall Call Centers Help Companies Avoid Distraction

When a company is faced with a product recall action, it’s unusual for them to have resources standing by to handle the influx of customer inquiries and additional work. That’s why so many companies turn to an outsourced product recall call center partner. A quality partner such as Realtime Results is ready on short notice with staffing, facilities and a proven process for handling a product recall.

A product recall call center provides companies with a valuable resource. It allows the company to keep its own employees focused on the work of growing their business and generating profits. Not to mention that few companies have the internal expertise to deal with the regulatory challenges of a product recall.

If you need product recall expertise or management, be sure to give the experts at Realtime Results a call. They can save you time, money and help you keep your focus.

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Are You Prepared For A Product Recall? Get External Recall Management Support!

Any company who produces a product faces the potential risk of a product recall. Companies that spend time to planning for product recall risk in advance are far better prepared to cope with the unexpected when it does happen. It’s the best course of action for minimizing the potential negative consequences to a company’s reputation.

By partnering with a product recall services and management company whose primary focus is managing product recalls, a company can ensure that they have an effective product recall management process is in place. Preparation in advance also helps to educate employees across the organization on the full implications of potential recalls.

When a recall strikes, transparent communications is the key to maintaining a positive relationship with consumers and regulators. But those transparent communications efforts are not helpful if they are not accompanied by quick and effective recall management, a process that can be streamlined and expedited by partnering with experts who have been there before.
Realtime Results provides comprehensive product recall services and product recall management. Our years of expertise in handling product recalls across a host of industries gives you a partner you can trust and a resource that will keep your employees focused on the parts of the business that make you money. Contact us today to know more about Realtime Results Product Recall Management Services.

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Realtime Results Launches Redesigned Product Recall Management Web Site

If you are visiting this Web site, then you’ve found our newly redesigned Web site for our product recall services. Our goal with this site is to better highlight and provide insights on our product recall services team and support offering.

“Product recall has become a significant business for Realtime Results,” explains Dan Hinkebein, Manager, Product Recall Business Services. “Companies have significant needs for product recall consulting and management when they find themselves facing a product recall. Our team of industry experts and product recall support teams are a valuable resource for companies in this situation.”

 

We have launched this new Web site to provide users with a deeper understanding of the breadth and depth of our product recall services. Over the next few months, the Web site will see continued additions and growth. As well, the new site gives us the opportunity to launch this new blog dedicated to discussing product recall industry news and product recall management trends and issues. We hope this blog will become a valuable resource for others in the product recall services space.

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Professional Product Recall Management & Planning

Whether you are facing a product recall action or simply preparing your organization, our team of product recall experts will help you to develop a comprehensive plan. Read more about our recall management and planning support.

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Product Recall Call Center Support

We are the leading provider of product recall call center services assisting companies across diverse industries. Read more about our recall call center services.

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Efficient Consumer Product Recall Services

The number of consumer product recalls is growing every year – companies large and small look to Realtime Results for assistance charting the regulatory waters.

Read more about our recall services.

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