In March 2018, the Department for Business, Energy and Industrial Strategy published a Code of Practice on consumer product safety related recalls and other corrective actions (PAS 7100:2018).
The Publicly Available Specification (PAS) was developed following consideration by the Working Group on Product Recalls and Safety and was facilitated by the British Standards Institution. The stated purpose of a PAS is to “respond to emerging needs within a sector, through a collaborative and robust process of knowledge sharing”. Whilst it does not have the status of a British Standard, and will be withdrawn once the content is incorporated into a British Standard, it is likely to be considered for development as a British Standard or to constitute UK input into the development of a European or International Standard.
The PAS sets out a Code of Practice for:
• businesses – to assist manufacturers, importers and distributors of non-food consumer products prepare to deal with product safety issues
• market surveillance authorities – to set out for local authorities and other regulators the guidance and advice that should be made available to businesses in order for them to meet their legal responsibilities and act in the public interest.
The PAS is aimed at all businesses, irrespective of size or type.
It places significant emphasis on the importance of advance planning, and provides practical guidance on preparation of a suitable Product Safety Incident Plan (PSIP).
A PSIP should include the following elements, setting out where possible who in an organisation has responsibilities for which action and when:
• product and customer traceability
• product safety monitoring
• market surveillance authority notification
• risk assessment
• corrective action planning
• PSIP training/testing/review plans
The PAS provides explanatory commentary under each of these headings.
It also sets out helpful summaries of the relevant regulatory requirements, together with model examples of risk assessment and notification documents.