What To Do With Recalled Products?
Apr/10
What do you do with all the products recovered from retail customers and consumers? Do you leave it to your retail customers or distributors to dispose of them? If not, where do you have the products sent to? Do they require certified destruction? Could they be re-formulated or corrected and then sent back out? What are the chances that your recalled products (and company name) could appear in headlines like this?
"Recalled products from a well known candy manufacturer being sold in Toronto area"
Chocolates and candies recalled two years ago over salmonella fears and subsequently stolen from a recycling depot are now being sold in Toronto-area stores, according to the Canadian Food Inspection Agency.
Once you have decided that a recall is necessary, the focus is understandably on removing affected products from the supply chain and advising consumers not to use the product and what to do with it. This in itself can be a hugely complicated and difficult task. Once this is in progress, the tendency may be to start to attend to all the other routine business-related issues that have slipped while you've been in "recall mode". But there is another vital step still to carry out; what to do with all the product that's been recovered.
In some cases, you will have advised consumers and customers to dispose of the product themselves. In other cases, it will have been returned to your own facilities. Maybe it's all stacked neatly and securely in your own warehouse and you already know a specialised and approved disposal facility close by that will destroy the product beyond any possible further use. In RQA's experience it rarely works like that.
For example, the returned stock in the warehouse may include a significant amount of "good" or non-affected stock. In addition, it is more likely that your stock will be located in several warehouses around Europe or beyond. Have you thought in advance about destruction firms in all those areas? If you're reading this and thinking "we're OK because we make a perishable food product and so there is no chance it will end up back in the supply chain", go to http://news.bbc.co.uk/1/hi/england/nottinghamshire/3190889.stm. This highlights how far criminals are prepared to go.
In addition to ensuring that recalled product cannot end up back in the hands of consumers, there is also the issue of increasingly punitive environmental legislation - there are still warehouses containing lead-contaminated toys that can't be incinerated or sent to landfill.
So what do you need to do to avoid the many potential pitfalls?
- Include storage and disposal of recovered product within your documented recall planning - assigning specific responsibility to a suitably senior person to ensure appropriate measures are in place before you actually need them.
- Pre-identify appropriate and secure storage and disposal firms in relevant geographic regions. Ensuring contact details and capabilities are kept up to date.
- Determine which methods of disposal are safe and legal for specific faults or contaminations.
- Consider where you send recalled product to; your manufacturing location or somewhere else? What are the implications of either?
- Ensure that the products will not fall into the hands of unscrupulous people who can then re-sell then?
- For exported products - the issue of who will store and oversee disposal of returned product is important. Be aware of what the legal obligations concerning disposal are in each market supplied. Even if landfill is a legally acceptable option, do you really want large volumes of your branded products sitting on a waste dump where it could easily resurface in the black market.
- Finally make sure that your procedures for disposing of any branded unused waste packaging (whether it's your or your customer's) do not make it easy for product counterfeiters.
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