On the 25 year anniversary of ICPHSO, much of the discussion centered around technologies most could never imagine when the organization began in 1993. Multiple sessions explored emerging technologies – both the undeniable upsides and the potential downsides when it comes to product safety.
During a standing room only session on lithium-ion batteries, panelists discussed the ubiquitous and potentially volatile nature of the product. There was a high-level explanation of how they are produced and the various ways the product can be compromised, including exposure to dust and particles or incorrect temperature and humidity controls. Attendees heard from an investigator who looks into incidents involving products that contain these batteries. After a fire, evidentiary artifacts – components that typically survive and those that sometimes do – as well as evidentiary data, such as the purchase date and charge/discharge history, can help determine whether the issue was caused by a defective battery. Using diagnostic equipment typically reserved for medical testing, such as CT scans and x-ray equipment, investigators can determine the manufacturer of the battery itself – not just the end product. While fires and, especially in the case of e-cigarettes, personal injuries currently dominate the number of incidents reported to regulators, one panelist expressed a suspicion that shock and electrocutions will rise as these batteries continue to become more compact and powerful.
No matter the type of incidents involved, the logistics of managing a recall involving lithium-ion batteries are complex, especially when it comes to transportation. For example, specialized packaging and labels may need to be ordered – which can often take time companies don’t have. One panelist pointed out that companies, especially large ones, have a team of people with vast experience managing product recalls – but have rarely been through one involving a lithium-ion battery. Without relying on expertise, companies often experience delays, Department of Transportation penalties, and – perhaps most costly – irreparable damage to crucial business relationships. The complexity is compounded when international recalls are involved. And the sheer scope can be overwhelming; many in attendance seemed surprised to learn that every product containing a lithium-ion battery that is subject to a safety recall is considered damaged from a shipping perspective – even when the individual items have no reported incidents and when the number of overall incidents has been relatively limited.
The Internet of Things
Like lithium-ion batteries, the Internet of Things presents enormous benefits, but also serious risks. Cyber criminals, certain nation states, so-called “hacktivists,” and terrorists all threaten to exploit vulnerabilities in systems such as smart locks and other home security products, appliances, medical devices, and more. At a session on the subject, panelists emphasized that the solutions must be multi-faceted, multi-stakeholder, and global. The internet has no boundaries.
Interestingly, from the Consumer Product Safety Commission (CPSC)’s perspective, safety questions do not include data security and consumer privacy issues. But certain cyber vulnerabilities could present a safety concern, including remote operation of products such as space heaters, a change in operation that causes unexpected operation of the device, or the ability to disable a safety feature such as a smoke detector.
The bottom line is that cybersecurity is unpredictable, which means manufacturers have a difficult time designing for it. But there are steps companies can take. For example, many companies may not be aware that malware is sometimes installed on component parts of devices, so it is crucial that companies know their suppliers.
On day two, an interactive panel walked attendees through a scenario involving situations that can arise from both technologies. How do companies handle media coverage and social media reports? What do you do when call centers are slammed? How do you know when to report to the CPSC and whether to participate in its Fast-Track program? Whether it is lithium-ion batteries, connected devices, or new technologies that haven’t even been dreamed up yet, it is crucial for companies to be prepared in advance. Developing a robust recall plan can help teams quickly answer these questions when a real-life scenario arises. They should understand the options – and limits – of connected devices in alerting consumers to recalls, installing fixes over the air, or simply shutting down and prompting consumers to take action. In another 25 years, the landscape will once again look very different – but the need for speed and effectiveness will remain.
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Reporting Adverse Events: FDA Seeks Comments on Revisions to Submission Forms https://t.co/919JeroD4O by @RAPSorg https://t.co/L87wZe8ITD
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