Tracking Label Requirement Still Vexes Suppliers and Distributors
Consider this scenario: You produce and import 150,000 bags in January, all in the same production run and all with the same tracking label. The bags arrive by ocean freight in March and you stock them in your U.S. warehouse. You decorate them over the next several months as you receive orders and by October you've shipped the last of them. The following April you receive a call from an investigator at the U.S. Consumer Product Safety Commission (CPSC) about that federal healthy food program. It turns out that a consumer advocacy group tested a few of the bags and found high levels of lead in the decoration. Your lawyer confers with the Commission and ultimately recommends that you initiate a "voluntary" recall. But how many bags do you have to include in the recall? You decorated and shipped 10,000 children's bags per month for the federal program in May, June, July, August and September. They all have the same imprint and the same tracking label. Do you have to recall all 50,000? What if the faulty ink arrived at your factory in September and was only involved in the final 500 pieces you produced? It would be a painful remedy to have recall 50,000 if the problem was limited to 500. In the end, the final tally will depend largely on your labeling, documentation, testing and record keeping. The more you know, the more you can document, the better off you'll be. If all you have is one tracking number covering five months of production how could you tell consumers to differentiate the high-lead bags from the earlier ones? But if you have a way to identify when each order was produced, then you could later use that to narrow the recall.
In this example, the high lead came from the decoration. That raises an important and related issue—developing a system to test and document the decorating materials you use. In this example, we noted that the factory received a batch of high lead ink in September. But if you do not have a system for testing or saving samples from each batch of ink, how could you later narrow down the problem to the ink you received in September?