I am hoping to solicit ideas and or best practices applicable to developing a recall strategy that allows the organization to manage recall rather than being at the mercy of the media. I am having difficulty rationalizing what is the best strategy to use where it is determined that a potential hazard exist and where sample collection and subsequent product analysis has not yet taken place. An example would be helpful, so here goes.
We receive a complaint implicating our product in an illness lets consider three (3) scenarios:
1) There are multiple complaints, no hospitalization is required no children involved.
2) There is one complaint and again no hospitalization and no children involved.
3) There is one complaint involving a young infant, no hospitalization involved.
The product is pasteurized milk, which is a RTE item but Listeria is not considered to be a threat (based on probability and occurrence) and there is evidence supporting normal functioning of the P.H.E in other words the sterilizer is not defective.
My problem is as follows:
Do I contact the regulatory authority, suspend distribution and concentrate on getting product and conducting an analysis? This delay could result in a loss of 2-4 days how do I justify not taking reasonable action to protect little “Jonnie" who consumed defective product 1 day after I held product at warehouse level only?
My leaning is to: contact the regulatory authority > stop distribution at warehouse level > stop store sales at retail - which will amount to destroying product since retail outlets will generally not hold product > issue a class 3 recall > proceed with product analysis > work with regulatory to finalize the recall class which may have to be elevated to Class 2 or Class 1.
In scenario one I have multiple so I would probably be supported. In scenario 2 I would probably get shot or worse. In scenario 3 it’s a cliff hanger, children, the elderly etc, this could be open season for the folks on the 6 pm news.
Clearly the decision is not mine, I am simply trying to anticipate the problem and make a responsible recommendation.
Has anyone gone through this exercise I would appreciate some of your wisdom.
Finally, I have gone through recalls where I waited 3-5 hours for the regulatory body to come back with a final decision and a recall class. My concern is that many companies inadvertently proceed like its the regulatory authority's recall, they are content to sit back and wait and see how it plays out. However, the notification never says “Regulatory ABC is recalling product X”, similarly the media never camps out on their door. Consequently, it it’s my recall I want to manage it so that my organization comes out credibility and brand image in tact.
Regards
Clemkonan
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