BulletProofBlog the blog on crisis communications

Each week, Bulletproof Blog features exclusive interviews with thought leaders on issues of critical importance to companies and countries. This week, as a follow up to our discussion of the Consumer Product Safety Improvement Act (CPSIA) with former Consumer Product Safety Commission compliance chief David Schmeltzer, we check back in with Mike Rozembajgier of Stericyclce' s Expert RECALL team.

Mr. Rozembajgier has helped hundreds of companies navigate the complex logistical, compliance, and communications challenges of more than 1,400 product recalls. A nationally-recognized expert in product safety crises and how the CPSIA is now significantly impacting the regulatory landscape, he shared his insights with Bulletproofâ„¢:

With strict new CPSIA recall standards in effect, what must companies be doing now to ensure they' ll be in compliance should a recall situation arise?

Mike Rozembajgier: Preparation has always been paramount in conducting effective recalls. Now that the strict new standards set forth in the CPSIA have taken effect, having a solid plan in place before a recall situation arises is absolutely essential. Has your recall team been assembled and do the members know their responsibilities? Have they come together to build the organizational trust that fast action demands? Are systems in place to collect the retrieval and outreach data that regulators will now be demanding? Has your supply chain been audited backwards and forwards?

These are the questions that every consumer product company needed to start asking themselves from the moment that the CPSIA passed. Now, if the answer to any of them is no, then you' re really behind the eight ball.

How have the ways in which companies must communicate with consumers, regulators, legislators, shareholders, and other stakeholders changed as a result of the new CPSIA standards?

Mike Rozembajgier: Consumers, retailers, and supply chain members need to hear clear, concise messages about the problems that led to the recall, the remedies being taken to ensure that the public is protected, and what the company is doing to prevent a similar occurrence in the future.

When it comes to regulators and legislators, they are going to want to know that the recall itself has been effective. That means having ready access to the hard data that demonstrates results. From proving that all affected products came off the shelves quickly to showing that your outreach efforts kept the public informed, the numbers are your strongest ally. Again, that comes back to planning. It' s about being ready to collect information about the recall from the minute it begins.

What' s next with regard to recall regulation? Are there issues emerging that consumer product companies need to be aware of?

Mike Rozembajgier: First of all, don' t expect the government' s focus on consumer safety to lose intensity. With Congress already discussing further legislative action and the White House firmly behind those efforts, the hoops that companies must jump through to ensure compliance are only going to multiply.

And second, we' re probably going to see the plaintiffs' bar leveraging any perceived misstep into big-dollar cases. Again, this means companies are going to have to be armed with the data that proves they acted in a responsible manner.

Larry Smith is Senior Vice President of Levick Strategic Communications and a contributing author to Bulletproof Blog.