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PAS 7100

PAS 7100: 2018 – Code of Practice on Consumer Product Safety Recalls and other Corrective Actions was published by the BSI in conjunction with the Department for Business, Energy and Industrial Strategy.  The guidance was developed with input from many stakeholders, including the British Retail Consortium, major retailers and manufacturers.  It is structured in two parts:

  • Part 1 – “Is intended for businesses offering non-food consumer products for sale and covers monitoring, assessing, notifying and correcting unsafe products, including through a recall or other corrective action…”; and
  • Part 2 – “Is intended for Market Surveillance Authorities and covers the assistance that should be available to businesses from such regulators (MSAs) to support them in meeting their responsibilities in respect of consumer product safety issues.”

We focus here on Part 1 and, in particular, Section 4 (“Advance Planning for Corrective Actions”) and Section 5 (“Managing a Corrective Action).

Section 4 – Advance Planning for Corrective Actions

This section gives specific guidance on the contents of a Product Safety Incident Plan (PSIP), which should include the following components:

  • Product and customer traceability plan;
  • Product safety monitoring plan;
  • Legal notification plan;
  • Risk assessment plan;
  • Corrective action decision plan;
  • Communications plan;
  • Training plan;
  • Testing plan; and
  • Review plan.

Each of these elements is then described in some detail.  Strangely, PAS 7100 makes no reference to any existing management systems; but, clearly, some of these issues may already be covered in the organisation’s quality management system or business continuity management system.  Even where issues are not already covered, it may make more sense to amend existing management systems to address these issues rather than document everything in a stand-alone PSIP.

Section 5 -Managing a Corrective Action

This section is a curious mixture of general guidance on incident management (once again, with no reference to other relevant standards, such as BS 11200: 2014 – Crisis Management Guidance and Good Practice); and more specific advice about responding to a product safety issue.  Unfortunately the latter involves some replication of information already covered in Section 4.  However, there are some very useful points in Section 5, including:

  • Checklist of possible corrective actions for a product safety issue;
  • Discussion of various options for returning, repairing and disposing of products; and
  • Short case studies of examples of good practice in product recalls.

 

 

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    Effective planning that takes into account risk evaluation and business impact analysis, supported by clear and concise crisis management. We work with you to develop user-friendly plans.

  • Business Impact Analysis

    The Business Impact Analysis (BIA) is one of the most important, and least well understood, stages of the Business Continuity Management Lifecycle; we can assist with your BIA.

  • Training and Exercising

    No Business Continuity Management programme is effective without a significant element of training. Moreover, ongoing Crisis Management training and exercising is key. We can provide objective training and exercising.

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    Risk evaluation and treatment provide a process to identify, prioritise and managing your risks. Cambridge Risk Solutions can assist with risk management for business operational and information security risks.

  • Statement of Applicability

    Which controls do you need to have in place? How do you link your risk assessment process into your SoA? How do you ensure that you have effective controls in place? We can assist with your SoA.

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    Management Systems assist with your on-going management, maintenance and continual improvement. We work with you to develop a fully integrated management system, enabling certification to ISO 22301 and ISO 27001.