The Five Stages Of Compliance Grief
Many things have changed in the promotional products industry since the toy industry suffered widespread recalls and product safety issues in late fall 2007. These events triggered the passage of the CPSIA in 2008, and product safety and compliance have been in the forefront ever since. Looking back, in many aspects, the way we used to do business has died. But in its place, a finer, stronger business model has emerged-one that is responsible socially, environmentally and has higher standards for quality and safety than ever before.
But like anytime there is a loss, there are mourners who yearn for the good ol' days. There are actually some interesting parallels to be drawn between The Five Stages of Grief and the path our industry has taken when approaching the topic of product safety and compliance.
People progress through the stages of grief at different rates, some moving much more quickly through it than others. Some get stuck in certain stages and need help from others to move through it. Those who can successfully navigate the grief often come out the other side of the experience as stronger people. To me, this sounds a bit like a description of how companies in our industry are finding their way through the complexities of the product safety and compliance situation.
To see what I mean, check out these these parallels:
- Denial or Minimization
This response is characterized by the many statements along the lines of: "Product safety and compliance do not apply to me," "Product safety and compliance are not important to my customers" or "We don't sell toys, so why should we be paying attention to these laws?" The reality is that we all have a legal and moral obligation to deliver safe and compliant products into the supply chain. Even if you perceive to have a low-risk product category, you-and your customers-can still get hammered by social accountability issues.
I was initially quite shocked at how strongly people were reacting to the topic of product safety and compliance. Supplier companies actually got very upset with their counterparts who were taking action and working to both understand and build compliance programs. Perhaps they were offended by the perceived implication that their products were not safe and compliant. And I would suspect there was some self-realization that they had been ignoring these topics for a long time and were being caught with their pants down. There was an initial industry backlash directed at the early adopters who recognized that the demand for product safety and compliance is not only the right thing to do but could also actually help them become a more valued partner for better distributors and their clients. Unfortunately, some companies are still stuck in this stage, which continues to baffle me. What compelling reason would you have to be upset, especially with other companies that have chosen to build compliance programs? Why would another company's actions on compliance upset you if you have nothing to hide?
This is an interesting phase because it shows that companies know they need to implement a comprehensive compliance program but they are not truly committed to doing it right. They are offering up FLA, WRAP or factories that are "insert-Fortune-50-company-here" certified as having a compliance program. Most of these companies have completed enough research to understand what must be done to do it right, but they are not willing to allocate the internal resources and/or money to actually do it. They are selling their customers an incomplete solution and trying to justify it. Many, many companies are stuck in this stage.
Here's where my analogy breaks down a bit, so I would replace "depression" with "confusion." Companies in this stage have come to realize that they need to do something, but they just don't know what. They begin to develop coping skills and pursue education that breaks down the complexity of the topic. They begin to formulate a game plan-but not a sense of urgency.
In the final stage, these companies realize product safety and compliance is here to stay and that they must move quickly to not only develop a comprehensive product safety and compliance program but to also implement it. Every day, I hear from more companies that have entered into this stage. And while the pace is picking up, we as an industry are still not where we could and should be. Looking back on where our industry was two years ago on the compliance topic, it is obvious that we have come a long way. We are moving slowly, yet inexorably, toward better solutions for Fortune 1000 clients. The truth is that every week, more companies are getting there. But the reality is that it often takes hard ROI-and even loss of business-before companies change.
For companies that have made it through to the other side, they have finally recognized comprehensive compliance programs offer both strength and a competitive advantage in a crowded marketplace. The ROI continues to build and is, in fact, accelerating.