When a company hears that it is involved in a federal product recall, the news can generate tremendous anxiety throughout the organization. Inevitably, questions will arise. Who made the mistake? Will our reputation be permanently damaged? Will we suffer substantial liability costs? How will we recover from this? In most cases, a company will incur considerable expense and dedicate many hours to resolving a recall situation. This is usually the point at which a management team is most motivated to develop a plan to prevent a recall from ever happening again.

The irony is that this scenario can often be prevented through third-party product testing before the first unit ever leaves the factory. The recall process works as well as it can, but it is clearly dealing with the aftermath of some process failure. Third-party testing typically occurs before any significant manufacturing has taken place and preferably while a product is in the design stage. Potential problem areas can be detected prior to the production process and before the product is introduced to the market. However, some manufacturers view third-party testing as an obstacle to getting products to market quickly and inexpensively. The added expense or time can make business owners and managers very uneasy as they decide how, or even if, their products should be tested by a third-party.

By no means should third-party testing be viewed as a panacea for product recalls. A quick review of the daily recall list reveals that a small percentage of recalled products are those that were or should have been evaluated to an appropriate standard and should be carrying a third-party safety marking. Changes in parts or materials being supplied to the manufacturer, or even the slightest change in the production process, can result in a recall. Despite that, the benefits of third-party testing are clear. Products that are not routinely submitted for third-party certification appear on the recall list approximately three times more often than those that are third-party certified.

It seems logical that an organization with no monetary interest in a manufacturing company can make clearer, unbiased decisions focused on safety. It is impossible to tally the lives saved or the injuries that did not happen because of a thorough safety evaluation. It is equally impossible to determine the number of recalls that did not occur because of such an evaluation. But just a cursory review of recall data for any recent time period reveals that the majority of recalls cite products that are not routinely submitted to a completely independent third-party certifier.

A thorough product evaluation often uncovers problems that would lead to a recall if not corrected. The products of even the most experienced manufacturers have problems that need to be addressed during a third-party evaluation. Simple design flaws that can cause rejection of a product include components that run too hot, enclosure openings that are too large, materials that are too flammable, or spacings that are too small. During the UL evaluation process, thousands of other aspects of products are checked, any of which could potentially cause a recall. It is easy to extrapolate that the number of recalls would double or triple if these products were to enter the marketplace without third-party testing.

It doesn’t require a big leap of logic to understand that recalls of untested products and their components could be reduced by a similar factor if tested by an independent third-party organization. To realize this gain, there are a number of concerns that manufacturers must overcome.

Manufacturers who are reluctant to pursue such evaluations commonly worry that the added time and cost of the testing could impede success of the product. There is no question that a thorough safety evaluation takes some time and that the expenses are borne by the manufacturer. However, when weighing the cost of a pre-market safety evaluation against product recall costs, it clearly makes sense to prefer lower cost of a pre-market safety evaluation.

One of the most important factors in the success of third-party testing is for the manufacturer to bring the testing organization into the discussion as early as possible. This single step helps save money in the long term and also helps the testing organization develop thorough test plans. Early involvement of the testing organization helps manufacturers to understand not only the standards that apply to a product, but also any federal or local laws that need to be considered. A further benefit of early submittal is that it gives manufacturers ample time to set up and fully integrate their internal quality assurance programs for the new product and its components.

Many of the stories one hears about unreasonably long safety evaluations can often be traced to a manufacturer that is unable, for whatever reason, to move quickly to rectify test failures. More importantly, a manufacturer deserves to have an evaluation done thoroughly and completely. One should be skeptical of organizations that promise to accomplish everything — including a long-term aging test — in just a few days.

It is true that only a very small fraction of the products on the market are ever recalled, and some manufacturers may wish to play the odds. However, a third-party evaluation can yield benefits beyond reducing the possibility of a recall. Safety evaluations certainly affect the overall quality of the product, even if that improvement is only in the area of increased safety rather than performance. A better product can affect sales and help eliminate breakdowns in the field. If a legal challenge should arise, the manufacturer is in a stronger position for having worked with an established, independent third-party safety testing organization.

Many manufacturers are also concerned about what standards will be used to test their products. There is no doubt, that having the proper standard is essential. However, for some products, there may not be an existing standard, or a standard may not completely address a product. The testing organization may have to pull together a variety of different standards and even develop some new requirements to thoroughly evaluate a product. And that should be viewed as an opportunity.

All of the major standards-developing organizations work very hard to gather input from as many resources as possible, giving all concerned parties a forum to discuss the pros and cons of each requirement. In many cases, the very federal or state regulators that could ultimately recall a product may be a part of the standards development process. When this occurs, the manufacturer receives good insight into the rationale for requirements while establishing a line of communications with both the testing organization and pertinent government agencies.

Reducing injuries, deaths and property damage through improved product safety is the goal of everyone involved, including federal regulators, third-party testing organizations, trade associations and manufacturers. The challenge is that, while everyone may have the same objective, they may have different approaches for achieving it.

All the stakeholders must work to establish a consensus. Federal regulators need to encourage more pre-market safety testing by independent third-party laboratories. Manufacturers need to make greater efforts to incorporate such testing into their plans and budgets. Trade associations need to better assist member companies in accomplishing these goals. And the testing laboratories themselves have to better understand the needs of the manufacturers.