Investigating the issue
After its preliminary assessment, the incident management (IM) team should thoroughly investigate the facts behind the product quality/safety issue.
Key actions include:
- obtaining all available information regarding reported problems from internal quality control, the consumer helpline, consumers and/or consumer protection or regulatory bodies
- establishing whether similar cases have occurred or are likely to arise (eg by reviewing related customer complaints records)
- considering holding release of product batches that may be affected
- consider tracing product batches which may be affected
- consider performing sampling exercises and/or spot-checks on existing stock items, as well as items in the distribution chain and on retailers' shelves
- where time permits, obtaining a technical analysis of the potential problem from in-house technical and/or quality control staff (any report should be reviewed by a qualified independent expert)
- maintaining legal privilege, where available, over such reports (see Controlling document creation and securing privilege)
Although it may take time to understand the full implications of the issue, the IM team should determine:
- whether the reports and/or complaints are genuine and, if so, what the potential issue is and where it may arise
- whether verified problems are isolated incidents (eg limited to one batch of product or one production base), or more widespread
- locations of potentially affected products (ie in the organisation's warehouse, in the distribution chain, or already sold to consumers)
- the degree and extent of risk to consumers (independent experts can assess the risk of the hazard arising and likely consequences if it does, including the potential impact on vulnerable groups)
Considering factors such as these should enable an informed assessment of any risk to individuals (and/or their property), including the likelihood of the risk materialising and its consequences.
You may have a legal duty to take action and notify regulators within a short period of time (see Dealing with regulators/reporting obligations). Remember that there will not always be time to conduct an exhaustive investigation before these obligations bite.
