Yesterday, on behalf of ICPHSO I attended the U.S. Consumer Product Safety Commission’s Recall Effectiveness Workshop. In my view, it was a significant day for several reasons. In the early morning hours, we heard that the White House issued a statement of its intent to nominate Acting Chairman Ann Marie Buerkle to the Chairman position for a full seven-year term beginning in October. This could provide CPSC with stability going forward that is always helpful for the staff and stakeholders. Second, the workshop developed and put on by CPSC Compliance staff under the direction of Deputy Director Carol Cave, offered a creative and comprehensive look at how to improve recall effectiveness. And third, it was a homecoming of sorts for me, returning to CPSC where I spent more than 40 years until my retirement, and becoming ICPHSO full-time Executive Director.
The energy and the enthusiasm in the workshop by the nearly 100 attendees representing many different stakeholders in the product safety community and CPSC staff was readily felt and appreciated. It was just like being at an ICPHSO Symposium since many of our regular attendees and members were present. There was great interaction between attendees, CPSC Compliance and other staff. All five CPSC Commissioners attended all or some of the workshop and were all actively engaged in the discussions. Everyone was interested in working towards finding suitable solutions to increase recall effectiveness to reduce injuries and deaths.
Blake Rose, Director, Defects Investigation Division started with an overview of the corrective action process and what the staff requires in a voluntary or mandatory recall. Blake’s presentation was followed by a presentation from Patty Davis, Acting Director of Communications, whose presentation provided a communications focus on what media likes to see in notices so that they will get reported.
Carol Cave, Deputy Director of the Office of Compliance then gave a presentation on recall data which provided attendees some new and useful information based upon an in-depth analysis conducted recently by CPSC staff looking at several years of recall data. Some of the data presented by Carol included:
- Review of closed cases between fiscal years 2013 and 2016 showed a surprisingly high 65% overall effectiveness rate;
- On average, 46% of section 15 reports to CPSC led to a recall or recall alert;
- Over a three-year period (2014-2016), 199 recalls used some form of social media notification;
- Recall Alert notifications (where the recalling company has the names of the majority of the purchasers of the recalled product) resulted in a greater consumer correction rate of about 50%;
- Generally, a higher recall correction rate occurs when consumers have multiple options for the recall remedy (repair, replacement, refund);
- Having the ability to reach consumers directly in the event of the recall generally results in a higher correction rate.
This data analysis will be a very useful tool going forward to guide both Commission staff and stakeholders, since having data related to past recalls can only help make future recalls more effective.
After a break for lunch which allowed attendees to network, the afternoon opened with a discussion on Communicating the Hazard moderated by Tanya Topka, Team Lead for the Fast Track Team in the Office of Compliance and Celestine Kish. Celestine is in the Human Factors Division at CPSC and has been actively involved with recall effectiveness issues for a number of years. She, along with Tanya who lives the issue day-to-day working with recalling companies, are well versed in the subject and brought out many issues for discussion among the attendees. There were also two breakout sessions. One was on Consumer Motivation moderated by Tanya Topka and Shelby Mathis, CPSC’s Small Business Ombudsman. The second breakout session included a large number of attendees who were interested in ways to Advance Technology to improve recall effectiveness. Because of the size of the group, it was split into three smaller groups. One group was moderated by Mary Toro, Director of the Regulatory Enforcement Division, in the Office of Compliance. The second group was moderated by Chris Nguyen, a Compliance Officer in the Defects Investigation Division, and the last group was led by Carol Cave and Pamela Chisholm, a Compliance Officer in the Defects Investigation Division.
The workshop was closed by the new Director of Compliance, Rob Kaye, who summarized some of the day’s highlights and indicated the presentations would be available on-line soon and hoped that the dialogue that was started would continue to come up with some viable solutions to improve recall effectiveness.
On behalf of ICPHSO, I commend CPSC and the staff for holding this important workshop and urge all in the ICPHSO community to review the staff presentation and workshop summary, once they are posted on the CPSC’s website. We look forward to continuing the dialogue to improve recall effectiveness at future ICPHSO Symposiums. And, on a more personal note, it was good to be back at CPSC (even if just for one day) and see many of my former colleagues, meet new ones and see many familiar faces from the product safety community, who took the time and had the interest in participating in the workshop. Next, I hope to see you all in Tokyo in November to continue the product safety dialogue.