Our clients often ask us what happens after a recall has been completed and what to expect from a visit from a regional CPSC inspector. We advise to be prepared to demonstrate what actions were taken regarding the Corrective Action Plan (CAP). The main purpose of the inspection appears to be to provide confirmation that CAP tasks (such as distribution of retailer letters and posters) are underway and/or have been completed.
The Commission staff will check that notice of the recall is available on the company website and often go to retail establishments to look for posters. The documents that an inspector may request at an on-site inspection include:
- Copies of all notifications to consumers and any other documents sent out regarding the recall;
- Copies or other demonstration that agreed social media was posted;
- If the company agreed to monitor wholesale/auction websites, records to show that such a process has been established;
- Records to demonstrate what the total number of units in the recall population, what inventory exists or what was done with any units under the company’s control at the start of the CAP;
- Incident records to confirm the total number of incidents, whether there have been new incidents discovered post-recall, and when the company first learned of incidents that gave rise to the CPSC filing.
Collecting and organizing these documents from the start can make the CPSC post-recall inspection much less time-consuming. And the inspection can provide an opportunity to resolve any problems that may have arisen in recall execution. Much of the information requested is necessary for completion of CPSC monthly status reports and can make that process work smoothly as well.