The Client: A Large Fortune 500 Retailer
In the highly competitive, tightly regulated, and heavily scrutinized retail industry, compliance is extremely important. Organizations need to manage and comply with multiple regulations including the Consumer Product Safety Improvement Act (CPSIA), the Fair Packaging and Labeling Act (FPLA), the Customs-Trade Partnership Against Terrorism (C-TPAT), and other local and regional regulations.
Apart from compliance, quality plays a critical role in an organization's success and even its survival. Retailers who sell products that contain potentially hazardous ingredients or defects not only invite regulatory penalties, but also negative publicity and possibly permanent reputational damage. Many have to recall their products from the market, incurring substantial losses.
Some recalls are often due to false or misleading product labeling. To prevent such incidents, regulators have issued several labeling mandates. FPLA, for instance, has very specific requirements around stating the identity of the product, the name and place of business of the manufacturer, packer, or distributor, and the net quantity of contents. FDA too, has strict requirements around labeling to ensure that products are free of contaminants and defects. Non-compliance with these labeling requirements can result in serious regulatory fines and lawsuits.
The MetricStream solution is enabling the client to efficiently manage these various legal and regulatory compliance requirements and issues. For product recalls and labeling compliance, the solution facilitates a streamlined and efficient approach to identifying, investigating, and resolving each issue before it gets out of control. Automated notifications keep the relevant personnel informed about compliance tasks, while powerful dashboards provide complete transparency into the end-to-end compliance and recall process.Download a Case Study
The client chose MetricStream Legal and Regulatory Compliance Solution for managing enterprise-wide product recalls and labeling compliance. The selection was based on the MetricStream solution's collaborative capabilities, underlying GRC platform functionality, and flexible and extensible data model designed to streamline and integrate issue and compliance management processes even in large corporations with complex organizational structures and diverse product and service lines.
The MetricStream solution covers the following areas in the client's organization:
If a product label is reported to be non-compliant with established norms, the MetricStream solution captures all the required information, and stores it in a single, centralized repository. It also sends out automatic notifications to the appropriate store managers, as well as department or product line managers.
For each labeling inquiry, an action item is created. A series of inbuilt questions help capture all inquiry details, including its origin -- be it a regulatory agency, direct QA, public interest organization, FTC, customer, or an internal source. Users can also upload multiple files to provide more information on the inquiry.
If a claim needs to be opened, the solution automatically notifies the risk user group, and helps enter the claim number and other necessary information. If a product is found to be non-compliant with labeling mandates, the solution captures all the required data -- including country of origin and content -- and triggers an investigation and resolution process.
If a product needs to be pulled from the shelves, the solution sends out automatic notifications to the relevant store department managers, and tracks the process till the managers have validated that they have completed the required action items. Alternatively, the solution notifies the relevant internal departments to initiate a "Do Not Sell" process.
The MetricStream solution is leveraged to handle all product recall issues across the enterprise. The solution captures the complete details of each issue, helping the client determine if the product needs to be recalled and, if so, why. It also determines where the issue originated, who it was triggered by (e.g. customer, regulatory agency, and internal resource), what type of issue it is (e.g. quality, IP), who needs to be notified, and which store the products need to be removed from.
Through a systematic approach, the solution facilitates in-depth investigations into each issue. If the product does not need to be recalled, the solution documents what was done, and archives all the investigation details in a single, centralized, and easily searchable system. It also helps execute and document mitigation steps, and communicate the same to the appropriate vendors.
If the product needs to be pulled from the shelves, the solution notifies the appropriate store department managers. It also provides flexible reports for store managers to indicate all the activities that they are performing to fulfill recall requirements.
Once a recall procedure has been triggered, the solution tracks that the recall has been communicated to customers, while alerting internal departments to report return rates. The solution also tracks if the Consumer Product Safety Commission (CPSC) has been notified about the relevant details.
Through seamless integration with supplier governance systems, the solution helps identify the supplier responsible for the product quality issue. This visibility allows the client to efficiently manage supplier chargebacks and related processes.
As a final step, the solution checks that all recall documentation has been finalized, and provides automated alerts to the appropriate departments to send and upload the required documents.
Vendor partnership survey
Labeling non-compliance or recall issues can sometimes be traced back to a vendor. To avoid such incidents, the client conducts regular vendor partnership surveys that confirm if all vendors have understood the appropriate labeling and quality policies, received sufficient training on these policies, and are consistently complying with them.
The MetricStream solution also streamlines and strengthens the efficiency of the survey management process. It helps ensure that vendors complete the survey within the requisite period of 90 days by sending out reminders to the recipients and their managers at regular intervals. It also enables users to fill in the surveys at their convenience by saving partially completed surveys, and working on them later.
The client faced a number of difficulties with their existing product recall and labeling compliance processes and systems, including:
The client chose MetricStream for the following reasons:
Scalability and flexibility:
The MetricStream solution and the underlying GRC platform are designed to support compliance and issue management processes even in large and complex organizations. It can quickly scale up to address growing requirements, while simultaneously integrating thousands of users across enterprise-wide business divisions and global locations.
The MetricStream solution is based on the MetricStream GRC platform, and can be extended, if required, to address other GRC needs such as risk management, audit management, and policy management.
Powerful business intelligence and analytics:
The MetricStream solution helps synthesize information from across the enterprise into coherent reports and dashboards which, in turn, enable leadership to understand the status of product recalls and labeling compliance, and the implications of their decisions.
The MetricStream solution has a sophisticated security model that maps each user to a specific role and organizational hierarchy unit. This restricts users from accessing information that does not pertain to their roles. They can only view the information meant for them through special in-built portals or InfoCenters.