Reducing Recalls through Third-party Testing

Each year, in order to prevent injury to consumers, Federal agencies in the United States recall hundreds of products. Product hazards may occur as a result of design flaws, production defects, tampering, unforeseen misuse of products, or failure to meet safety standards.

Defective products have also been an area of growing concern among Asian countries. In China, a defective product recall system was established in 2004, with an experiment on recalling defective automobiles. The purpose of the system is to eliminate the danger to people and property that various products bring about due to their systematic defects.

When a company is involved in a product recall, it has to face a series of repercussions including serious fines and brand crisis. The company needs to take a number of remedial actions such as changing product design and packaging, withdrawing products from the distribution channels, announcing the product hazards to the public, as well as offering replacements or refunds. The substantial efforts and resources involved in resolving a recall situation would motivate the management team to prevent a recall from ever happening again.

In fact, product recalls can often be prevented through third-party product testing. Third-party testing typically occurs before any significant manufacturing has taken place and preferably while a product is in the design stage. Potential problem areas can be detected prior to the production process and before the product is introduced to the market. However, some manufacturers view third-party testing as an obstacle to getting products to market quickly and inexpensively. The added expense or time can make business owners and managers very uneasy as they decide how, or even if, their products should be tested by a third-party.

By no means should third-party testing be viewed as a panacea for product recalls. A quick review of the daily recall list reveals that a small percentage of recalled products are those that were or should have been evaluated to an appropriate standard and should be carrying a third-party safety marking. Changes in parts or materials being supplied to the manufacturer, or even the slightest change in the production process, can result in a recall. Despite that, the benefits of third-party testing are clear. Products that are not routinely submitted for third-party certification appear on the recall list approximately three times more often than those that are third-party certified.

“Products that are not routinely submitted for third-party certification appear on the recall list approximately three times more often than those that are third-party certified.”

A thorough product evaluation often uncovers problems that would lead to a recall if not corrected. Simple design flaws that can cause rejection of a product include components that run too hot, enclosure openings that are too large, materials that are too flammable, or spacings that are too small. During the UL evaluation process, thousands of other aspects of products are checked, any of which could potentially cause a recall. It is easy to extrapolate that the number of recalls would double or triple if these products were to enter the marketplace without third-party testing.

An important factor in the success of third-party testing is for the manufacturer to bring the testing organization into the discussion as early as possible. This single step helps save money in the long term and also helps the testing organization develop thorough test plans. It helps manufacturers to understand not only the standards that apply to a product, but also any national or local laws that need to be considered. A further benefit of early submittal is that it gives manufacturers ample time to set up and fully integrate their internal quality assurance programs for the new product and its components.

It is true that only a very small fraction of the products on the market are ever recalled, and some manufacturers may wish to play the odds. However, a third-party evaluation can yield benefits beyond reducing the possibility of a recall. Safety evaluations certainly affect the overall quality of the product, even if that improvement is only in the area of increased safety rather than performance. A better product can affect sales and help eliminate breakdowns in the field. If a legal challenge should arise, the manufacturer is in a stronger position for having worked with an established, independent third-party safety testing organization.

Many manufacturers are also concerned about what standards will be used to test their products. There is no doubt, that having the proper standard is essential. However, for some products, there may not be an existing standard, or a standard may not completely address a product. The testing organization may have to pull together a variety of different standards and even develop some new requirements to thoroughly evaluate a product.

All of the major standards-developing organizations work very hard to gather input from as many resources as possible, giving all concerned parties a forum to discuss the pros and cons of each requirement. In many cases, the regulators that could ultimately recall a product may be a part of the standards development process. When this occurs, the manufacturer receives good insight into the rationale for requirements while establishing a line of communications with both the testing organization and pertinent government agencies.

“If a legal challenge should arise, the manufacturer is in a stronger position for having worked with an established, independent third-party safety testing organization.”

Reducing injuries, deaths and property damage through improved product safety is the goal of everyone involved, including regulators, third-party testing organizations, and manufacturers. While they may have different approaches for achieving it, all the stakeholders must work to establish a consensus. Federal regulators need to encourage more pre-market safety testing by independent third-party laboratories. Manufacturers need to make greater efforts to incorporate such testing into their plans and budgets. And the testing laboratories themselves have to better understand the needs of the manufacturers.