WASHINGTON, DC - Nancy Harvey Steorts, an expert in the field of safety, played an integral role during the recent toy jewelry recall. She served as advisor to the four importers involved in the recall, guiding them through the seemingly daunting recall process. As a former chairperson of the U.S. Consumer Product Safety Commission and author of several books on consumer safety, Steorts's Washington expertise in the field of product safety made her an invaluable asset. VT interviewed Steorts to get answers to some of the most frequently asked questions about the toy jewelry recall.
VT: The four suppliers involved in the CPSC recall have credited you with playing a key role in their ability meet the challenge successfully. Can you provide some information on the role you played as consultant? And, how does this recall stack up against other recalls in terms of effectiveness?
STEORTS: Yes, I did play a key role in the toy jewelry recall. As an advisor to the four importers, A&A Global Industries, Brand Imports, Cardinal Distributing and L.M. Becker & Co., I gave them strategic direction and assistance in the handling of the recall of the toy jewelry. As the former chairman of the U.S. Consumer Product Safety Commission, I gave them advice on how to handle the situation, and helped them design their strategy. I also served as their national spokesperson and assisted them in explaining the recall and their actions to the media. The importers were outstanding industry leaders and pledged to do right for their customer , the consumers , as well as for their industry. Safe products and the safety of the customers was their number one priority. In my opinion, this recall although difficult, was extremely effective and serves as a model for other industries to emulate.
Those involved in the bulk vending industry are famously independent-minded, entrepreneurial individuals. Given that, the question has arisen that we're dealing with an intrusive government bureaucracy. Could you provide some information on the CPSC, and would you say this recall was justified?
The U.S. Consumer Product Safety Commission is an independent regulatory agency that reports directly to the U.S. Congress. It is presently comprised of three commissioners who are appointed by the president of the United States and approved by the U.S. Senate. The staff of the CPSC is extremely competent, very professional and very accomplished in their areas of expertise. Many of the key officials have been at the CPSC since the inception of the agency in 1973. They are dedicated public servants whose major role is to protect the consumer in the marketplace. The CPSC is a very powerful regulatory agency, and has as its mission the protection of the consumer in the marketplace. The agency works cooperatively with industry, but has very broad regulatory authority. Yes, the recall was justified.
In an interview, the CPSC has called the actions of the industry "laudable." However, some in the industry have voiced the opinion that the four importers went too far and that the recall was too expansive. Why was such an extensive recall the best of all possible options under the circumstances?
Yes, the CPSC saw the actions of the industry as exemplary. The four industry leaders, who import approximately 90% of the metal toy jewelry, were outstanding in the way they handled this recall. I strongly believe that this was a "model recall" and demonstrated to the CPSC, to industry, to the consumer and to the media how industry leaders should handle a product problem, if it occurs. The importers of metal toy jewelry felt that it would be very confusing to both the operator of vending machines and to the consumer to differentiate between jewelry that had lead, and those which did not. Although they were only required to recall 10 items, they decided to recall 150 items, to alleviate any confusion in the marketplace. In a cooperative agreement with the CPSC, they pledged to work together to better define a level of that lead that would be unharmful to children.
This recall, although very extensive, was the correct one, and resulted in the "right way" to handle such a recall. If this had not been done in the way it was, it could have possibly resulted in more recalls in the future, because of the lack of a precise decision by CPSC on the lead content of the jewelry that would not be potentially harmful to children.
Even a cursory look at the CPSC website shows a long list of recalls involving some of the nation's largest companies, the vast majority of which are still regarded as good "corporate citizens."
Should those in the bulk vending industry take that to mean that a recall by the CPSC isn't the business equivalent of a "scarlet letter" in the eyes of the general public?
A recall is not a "scarlet letter" in the eyes of the general public. A recall can happen to any corporation; the key is how a corporation handles the problem. The key is to handle the problem effectively, quickly, and not to throw up unnecessary "road blocks." One hopes not to have to go through a recall, but it can happen. The way the four importers handled this recall was outstanding, exemplary and a credit to the bulk vending industry. This recall is being viewed as setting the new standard for how a recall should be handled. The distributors/operators who buy from these importers should know that these importers are trying to do everything in their power to bring safe products into the marketplace.
There is much concern in the industry as to what happens next. Given your experience with other recalls, can you offer a guess as to how this recall will impact the industry in the long term, and, how other industries have dealt with the effects of a large recall?
The recall is proceeding. The vending machines are being cleaned out. The importers are working in cooperation with the CPSC on the lead issue. They will not import any toy-metal jewelry until they get the "green light" from the CPSC. The CPSC, the media and others are applauding the industry for the way it handled this situation. The long-term effect for the bulk vending industry should be positive. This recall demonstrated that if a problem should occur, it can be handled professionally, effectively and correctly. When I was chairman of the CPSC, I handled the Tylenol child-resistant closure issue with Johnson & Johnson. Instead of resisting the potential recall, Johnson & Johnson "stepped up to the plate" and rectified the problem immediately. The Tylenol issue at that time was the model of how to do a potential recall correctly. The handling of the Tylenol issue is still the "case study" for effective recalls in most leading business schools throughout the U.S. Examples of very poor recalls are Bridgestone tires, Jack in the Box hamburgers, urea-formaldehyde insulation to name a few.
During the course of the entire process, much was made about the testing. The importers of toy fashion accessories tested their products through independent labs, yet the CPSC still deemed the products a hazard. Is this a common occurrence or was the ruling somewhat anomalous in that neither the industry nor the CPSC could have anticipated the potential danger?
The reason a manufacturer or importer uses a testing lab is to be assured that the product passes all U. S. regulations. CPSC does not do testing; it sets the standards and guidelines which testing labs should adhere to. I think it is extremely important that all reputable testing labs know all of the current regulations, and guidelines, so that the customer can be told if a product should have a potential problem.
Over the last several years the bulk vending industry has evolved at a relatively rapid rate with new products and new categories of products appearing nearly on a monthly basis. What can the industry do to guard against future recalls?
The bulk vending industry should have Washington representation that can monitor the rules and regulations, and know what new regulatory trends are taking place so that industry can be knowledgeable. It would also be very advisable to have "safety seminars" at annual meetings with representatives of the regulatory agencies that affect the industry. I would also advise working with the top leadership of reputable testing labs; have testing programs specifically designed for bulk vending products; be at the forefront of government interaction; and be proactive.
From your experience, what are the long-term effects, if any, of such a recall on a relatively small industry such as bulk vending?
This was a wake-up call for everyone. Because of the way the importers handled this recall, I do not think there will be any long-term negative effect. I think that these importers demonstrated to the country their concern for safety, and their concern for children. It also demonstrated the excellent history of the bulk vending industry. The actions taken over the last few weeks show that when or if there is a problem, it will be resolved, quickly, and effectively, in order to preserve an enviable industry safety record.
Nancy Harvey Steorts serves as an advisor to companies facing product safety issues, and is also the author of two highly praised books on safety issues. She has used her decades of experience in the field, including a stint as the chairman of the Consumer Product Safety Commission, to write these guides. Her most recent book, Safe Living in a Dangerous World: An Expert Answers Your Every Question from Homeland Security to Home Safety, provides readers with up-to-date answers on a wide variety of safety-oriented questions spanning topics from terrorism to recreation. A comprehensive guide, Safe Living contains more than 200 pages that provide literally hundreds of informative tips, instructions and guidelines, as well as numerous checklists, on subjects as wide ranging as baby furniture and first aid to fire hazards and traveling abroad. Safe Living is available from Capital Books. Steorts' earlier book, Safety and You (Syracuse University Press), also covers a wide range of safety topics, primarily focusing on the home.