Five Things to Remember Before, During and After a Recall

John Brandt (L) & Mark Paustenbach

At some point, every company that produces consumer or commercial products will face questions or a crisis related to the effectiveness or safety of what they sell. Product recalls are quite common, with thousands occurring due to mandates from state and federal regulators. Already in 2021, the Consumer Product Safety Commission and the Food and Drug Administration combined have issued over 100 recalls and market withdrawals to date.

If not handled properly, they have the ability to hurt brand reputation and sales, impact unrelated products and benefits competitors.

While recalls are by definition unexpected, organizations can take steps to shorten their duration and lessen their impact. Here are five things to remember before, during and after an incident.

1) Before: Preventative maintenance

A crisis response plan should answer the following questions.

• What could go wrong? Perform risk analyses and vulnerability audits for products or services that are well-known publicly and are likely to generate significant media interest if recalled.

• What do we say? Draft background points and holding statements that can be modified depending on the circumstances. It is far better to think about messaging before being bombarded with inquiries from customers and the media.

• How do we say it? Identify the best spokespeople for public comments, whether through a written statement, interacting with reporters, or appearing on radio or TV. These individuals should be thoroughly media trained.

Make clear to non-communications employees how, where and when they should talk about a crisis. Having a system in place to interact with team members will facilitate information sharing and lessen the likelihood that employees will go outside the organization to discuss the event or get additional information. When sharing information, keep messaging consistent, as it may become public.

2) Before: Communications channel audit

Every organization should determine which channels will be used to communicate and which will be kept clean. When the crisis hits, staff should be able to use the agreed upon channels—social media, press release or company blog—to place recall information and holding statements.

All of the company’s other communications assets, particularly social channels that have public or user-generated content components, like Facebook or Twitter, should be monitored and audited. If the company has other unaffected brands, they should be watched closely to ensure that recall-related content does not spread there.

Organizations should have a plan to monitor these channels at all hours. Virality does not just work from 9 to 5.

In addition to communications channels, it is important to identify the best spokespeople for the company, depending on the threat level. Some events will only need a comment from the public affairs team. If it is significant enough, a public statement from the CEO or a senior executive might be needed.

Find third-party surrogates who will speak on the company’s behalf as facts are still being gathered. If the company engages in influencer marketing, have a plan to share necessary information and inform them of what they should and should not be saying about an incident.

3) During: Determine posture

Is it best to be out there publicly to control the narrative and provide facts in a timely manner or keep statements to a minimum and wait for the moment to pass? This will be determined by many factors, including, but not limited to, the following: how widespread is the recall, what is causing the recall, how common are recalls in this category, and how essential is the affected product to overall brand health and reputation.

Whether the organization wants to engage with the press or not, clear communications with consumers about what they need to do to comply with the recall is essential.

When speaking on an issue involving public safety, reiterate your commitment to customers and discuss resources available to those affected, such as a hotline or dedicated customer service team. As appropriate, offer details about the various steps being taken to address and remediate any problems.

4) During: Regulator relationships

All of these decisions may depend on forces outside of your normal control as a business. This is doubly true for specific legal considerations, as well as the roles of state and federal regulators, non-governmental organizations, or industry stakeholders.

Coordinate your communications efforts with counsel to ensure that public statements do not negatively impact legal matters. Those interfacing with regulators must be looped into crisis planning to avoid developments that may catch either party by surprise. The same is true for industry stakeholders and relevant trade associations who could support and validate your response.

Frequent critics of the company should be monitored as well, and any engagement on the issue should be brought to the crisis team.

5) After: Evaluation, education and renewed preparation

Following the recall, it is important to take stock of how the situation was handled. Your leadership team will need to have an honest discussion about what went well, what didn’t, crisis duration, coverage and any sentiment/market share impacts.

Establish a clear narrative of what happened, how you reacted and the end results. The analog would be an NTSB accident report that outlines all the events leading up to the incident, with the addition of steps taken to resolve the issue. Having a clear storyline will help companies refine and optimize plans as they head back to step one.

These steps may not prevent all crises, but in our experience, advance planning and a careful analysis of previous experiences will allow public affairs teams to take immediate action. Pursuing the necessary strategic steps before a crisis hits will allow organizations to move to recovery efforts sooner.

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John Brandt is a vice president and Mark Paustenbach is a senior vice president at ROKK Solutions, a Washington, DC-based, bipartisan public affairs firm.