The Health Canada 12-Step Recall Process ;-)
Did you know that Health Canada has an actual 12-step process for recalling hazardous consumer products in Canada? It’s true and I know this because Alex Toys is telling me that they “have worked with Health Canada on the requirements for the recall and are following their prescribed actions”. You know what, they’re right.
The Health Canada website provides an informative industry guide for recalling consumer products in Canada. Specifically, the “guide is intended to assist you as an importer, manufacturer, distributor, wholesaler, or retailer of consumer products to complete an effective recall of unsafe consumer products from the marketplace”. The industry guide also provides definition on what is a recall, when to recall, why recall, and then my favourite section “How to Complete a Product Recall?”.
The How to Complete a Product Recall is actually a defined 12-step process and the Coles Notes version is to first identify that you have a recall and designate someone with the authority and responsibility to follow out the recall process. This responsibility includes isolating any existing products, distributing the very factual recall notice (who, what, where, when, why, how many, and what to do, and contact information - in both official languages), directly contacting the resellers of the product and informing them of the factual recall notice, and then following up to measure the success of the recall.
I was probably the only person in Canada that tested the accuracy of this particular recall by visiting both online, and bricks and mortar stores this weekend so my test pool is small, but this is what I concluded:
- Manufacturers and retailers are not posting their consumer toy recall notices to their websites.
- Manufacturers and retailers are not posting their consumer toy recall notices in plain and open sight of consumers.
Do you know why? Because they don’t have to.
Thankfully, Health Canada identifies what products have been recalled, but then indicates to the industry that it “may be necessary to quickly notify consumers if unsafe products are in the Canadian marketplace”, or “to warn consumers, your company may produce and distribute a media release, newspaper advertisement, display signs or point of sale posters to display in retail outlets where the recalled products were sold, and/or post the recall on your company website.”
But what this doesn’t say is that manufacturers of recalled toys have to coordinate any communication of the recall to consumers. Honestly, imagine the advertisements:
using the Flippity Flop product may cause adverse health effects such as nausea, vomiting, diarrhea and cramps as well as more severe symptoms. Children’s toys coated with paint containing barium, in excess of the allowable limit, are strictly prohibited in Canada.
Not recommended for children under the age of 15
or
This toy is not recommended if you are also using [Insert another recalled toy here].
One thing that Health Canada is very clear to the industry about is that if you are going to publicize your recalls ils devraient être dans les deux langues officielles.
