Recall
Recall
Product recall is a process of collecting product and returning it to the point of manufacture or distribution if they are unsafe or likely to cause injury through use or misuse. Product recalls can be voluntary (initiated by the business/supplier) or mandatory (initiated by a government authority). Many producers of product demonstrate their recall readiness through a documented and tested process of traceability, recall training, recall assessment, decision-making and threat assessment.
A business’ future continuity, share value, Net Promoter Score and existence can be threatened by a poorly managed recall or product withdrawal. Success relies on the ability of a business to lead its recall team through the stages of recall or withdrawal and even crisis management. All too often we see business and leaders try to avoid or evade responsibility and accountability and it always ends, familiarly, with personnel exits, business devaluation and brand and reputation impacts.
Working with experts that are independent and objective to your business can provide a much-needed lens on recall readiness. We provide recall plan consulting that takes a holistic approach to your business and elevates the process to one of capability and confidence to make sound decisions, based on fact and data, at precisely the right time. The outcome is a confident leadership of recall or withdrawal that delivers clear success indicators, sound communications and consumer confidence.
Recall Plan Review
A Recall Plan review includes an analysis of the company’s knowledge of legal requirements and their preparedness to analyse potential violations and make decisions on what to do about it. Includes regulatory requirements and common law requirements.
Any documented procedures will be reviewed against 10393:2013 Consumer product recall — Guidelines for suppliers. A desk review will identify compliance to the Standard, and any gaps or risks not managed through the documentation.
A report will be generated highlighting review and the compliance to the Standard.
Recall Simulation
This simulation involves bringing together the crisis management team, using the recall management tools and interacting with staff. A specific scenario will be developed covering a realistic situation and will be conducted over 4-6 hours. The decisions and communications of the crisis management group are monitored and recorded during the exercise. The program takes the following steps:
- Design of a recall simulation, including selection of product line;
- Development of the simulation, including selection of batch codes, affected customers, root cause, in-process documentation, social media, etc, product traceability forwards to customer and reverse to raw material suppliers;
- Enactment, convening of the crisis team, defining the recall assessment terms, highlighting the simulation parameters, enacting the recall simulation using the documented company recall plans;
- Wrap Up events once recall procedure has been enacted and the simulation has reached a conclusion;
- Reporting of the recall readiness against the procedure and the recall assessment checklist.
An assessment score of >80% indicates the organisation’s ability to successfully manage and learn from a recall or crisis. Any organisation scoring between 60-80% will be required to be reassessed within a twelve-month timeframe. Any organisation scoring between <60% will be required to be reassessed within a six-month timeframe.
Crisis Management Review
Crisis management is a critical organisational function. Failure can result in serious harm to stakeholders, losses for an organization. A crisis can create three related threats: (1) public safety, (2) financial loss, and (3) reputation loss. Effective crisis management handles the threats sequentially. The primary concern in a crisis has to be public safety. Ultimately, crisis management is designed to protect an organization and its stakeholders from threats and/or reduce the impact felt by threats.
Crisis management can be divided into three phases: (1) pre-crisis, (2) crisis response, and (3) post-crisis. The pre-crisis phase is concerned with prevention and preparation. The crisis response phase is when management must actually respond to a crisis. The post-crisis phase looks for ways to better prepare for the next crisis and fulfils commitments made during the crisis phase including follow-up information. The HPS view of crisis management serves as the organizing framework for you.
HPS offer support using the three phases:
Pre-Crisis
- Review crisis management plan and update it at least annually;
- Review a designated crisis management team that is properly trained;
- Conduct exercise at least annually to test the crisis management plan and team; and
- Pre-draft select crisis management messages including content for dark web sites and templates for crisis statements.
Crisis Response
• The initial crisis response; and
• Reputation repair and behavioural intentions.
Post-Crisis
- Deliver all information promised to stakeholders as soon as that information is known;
- Keep stakeholders updated on the progression of recovery efforts including any corrective measures being taken and the progress of investigations; and
- Analyse the crisis management effort for lessons and integrate those lessons into the organization’s crisis management system.
Pre-Crisis Consulting
Pre-crisis support with HPS involves seeking to reduce known risks that could lead to a crisis. This should also be part of the risk management program. HPS will review the existing crisis management plan, review and test the crisis management team’s skills, and conduct exercises to test the crisis management plan. HPS wishes to ensure the crisis management plan is updated at least annually, have a skilled crisis management team that is crisis-ready, and pre-draft some crisis messages. This planning and preparation allow the crisis team to react faster and to make more effective decisions.
Review Of The Crisis Management Plan
A crisis management plan (CMP) is a reference tool, not a blueprint. A CMP provides lists of key contact information, reminders of what typically should be done in a crisis, and forms to be used to document the crisis response. A crisis management review includes an analysis of the company’s knowledge of legal requirements and their preparedness to analyse potential violations and make decisions on what to do about it. Includes regulatory requirements and common law requirements.
Any documented procedures will be reviewed against ISO22301:2012 Societal security – Business continuity management systems. A desk review will identify compliance with the Standard, and any gaps or risks not managed through the documentation. A report will be generated highlighting review and the compliance to the Standard.
A CMP is not a step-by-step guide on how to manage a crisis. HPS will review the following criteria:
- Crisis Team Composition;
- Clear functions and authorities;
- Pre-assigned tasks;
- Decision-making methods;
- Performance measurements;
- Pre-collected information; and
- Available reference materials and resources.
Spokesperson Development
A key component of crisis team training is spokesperson training. Organizational members must be prepared to talk to the news media during a crisis. HPS will work with communications personnel to create media training. The Crisis Media Training Best Practices have been referenced and would include:
- Avoiding the phrase “no comment” because people think it means the organization is guilty and trying to hide something;
- Presenting information clearly by avoiding jargon or technical terms;
- Appearing pleasant on camera by avoiding nervous habits that people interpret as deception; and
- Briefing all potential spokespersons on the latest crisis information and the key message points the organization is trying to convey to stakeholders.
Pre-Drafted Messages
HPS will assist you to pre-draft messages that will be used during a crisis. Templates include statements by top management, news releases. Public relations personnel can help to draft these messages. The legal department can then pre-approve the use of the messages. Time is saved during a crisis as specific information is simply inserted and messages sent and/or made available on a web site. Communication Channels
HPS will work with key personnel to determine the needs for any separate web sites for crisis or designate a section of its current web site for the crisis.
Crisis Response
The crisis response is what management does and says after the crisis hits. Public relations play a critical role in the crisis response by helping to develop the messages that are sent to various publics. HPS will work with you to assist in the delivery of:
- the initial crisis response; and
- reputation repair.
INITIAL RESPONSE
HPS will work with you to create a clear set of guidelines for how to respond once a crisis hits. The initial crisis response guidelines focus on three points: (1) be quick, (2) be accurate, and (3) be consistent. The rationale behind being quick is the need for the organization to tell its side of the story. People want accurate information about what happened and how that event might affect them. The philosophy of speaking with one voice in a crisis is a way to maintain accuracy. HPS will work with you to ensure these principles are delivered during the crisis event.
REPUTATION REPAIR AND BEHAVIORAL INTENTIONS
HPS will follow a two-step process to assess the reputational threat of a crisis. The first step is to determine the basic crisis type. HPS considers how the news media and other stakeholders are defining the crisis. The second step is to review the intensifying factors of crisis history and prior reputation. If you have a history of similar crises or has a negative prior reputation, the reputational threat is intensified. HPS will then work with key personnel to identify reputation repair strategies to ensure they accommodate victims of crisis (those at risk or harmed by the crisis). Accommodate means that the response focuses more on helping the victims than on addressing organisational concerns.
If you promised to provide additional information during the crisis phase, HPS will work with personnel to ensure all commitments are met. HPS will focus on the delivery of those informational promises to minimise any risk of losing the trust of the public wanting the information. Second, you need to release updates on the recovery process, corrective actions, and/or investigations of the crisis. HPS will monitor the amount of follow-up communication required depending on the amount of information promised during the crisis and the length of time it takes to complete the recovery process.
POST-CRISIS PHASE
The crisis management effort needs to be evaluated to see what is working and what needs improvement. The same holds true for exercises. HPS will work with key personnel to review every crisis management to ensure outcomes are treated as a learning experience. You should seek ways to improve prevention, preparation, and/or the response once the review is completed. Reports will be prepared and presented to key personnel to understand the capabilities of the organisation and the competencies of the personnel performing crisis management.