Recalls are a test of record-keeping

The announcement of a recall attracts all the attention. It is also the easy part. The difficult part is what follows: months or years of reporting on how many units have been recovered, how many are outstanding, and what has become of the rest. That reporting is where a recall succeeds or fails in public, and it depends almost entirely on records.

In the recalls I have advised on, the questions that caused most trouble were never about the product. They were about the paperwork. How many units were made? How many were shipped, to whom and when? How many have come back, and how do you know? Where a manufacturer’s own records disagree with each other, or with a regulator’s, the disagreement becomes the story, and it is a story about competence that no statement can fix.

Before a recall

• Know how many units you made, and be able to show it from more than one record.
• Know where every unit went, and what document records its arrival.
• Decide in advance what counts as “recovered”, and write it down.
• Make sure the people who sign for returned units sign in a way that can be checked later.

During a recall

Report on a fixed day, every month, with the same figures in the same form, and explain any change in method before you use it. A recall report that changes shape from month to month invites the question of what it is hiding, even when it is hiding nothing.