When it Comes to Your Supply Chain, Who is Your Weakest Link?

Perhaps the most recognizable supply chain challenge linked to a product recall is the Takata airbag recall, which has so far impacted 19 automakers and 37 million vehicles over the course of several years. Because of the growing global length and complexity of supply chains, most product recalls today bring added layers of liability and reputational risk for several companies.

We discussed the importance of supply chain integrity following the recent Growers Express produce recall. Food companies, in particular, know far too well that one contaminated ingredient can result in a string of recalls impacting several brands. And when that happens,  it’s seldom the supplier’s reputation on the line. It’s a crisis for the consumer-facing brand.

Now the risks suppliers pose to manufacturers are hitting home for the cosmetics industry. Why? Because of a single substance with myriad uses: talc.

The FDA recently updated its consumer advisory about cosmetic products to include a new recall of four products by Beauty Plus Global. The cosmetic products were recalled after testing positive for asbestos. While the recall notice doesn’t explicitly mention talc, the FDA’s advisory includes a link to the agency’s Talc page which discusses asbestos contamination in cosmetics.

Meanwhile, the Environmental Working Group has been tracking talc in cosmetics as part of its Skin Deep® product database. According to the EWG, more than 2,100 products – including soaps, liquid products, loose and pressed products, and aerosol sprays – contain talc as an ingredient.

Connecting the dots here isn’t hard. Talc is in headlines for issues related to asbestos and other alleged human health risks. Consumer advocates are investigating talc and the products that contain it. And FDA is aware and watching closely. So while we don’t know how many products that contain talc are contaminated with asbestos, one thing is for sure: We’ve not seen the last talc-asbestos recall.

So how do you protect yourself? There are a few immediate steps we recommend you consider:

1. Require your suppliers to certify the safety of the product they send you. If they aren’t willing, or can’t, that should raise an immediate red flag. We appreciate that it may not be a deal-breaker, but you should evaluate the risks and make an informed decision on the supplier and the product or ingredient you plan to use.

• Do your own sampling and testing. Even if your supplier certifies the product they send you, we recommend you not blindly accept their statements.If they aren’t willing or able to guarantee the safety of the product they send you, the ability to test the product on your own becomes even more critical.

• Review and refresh your crisis plan. Accidents happen and sampling can’t catch everything. So even if you’re confident in your efforts to button up your supply chain, you should be reviewing, updating and testing your crisis and recall plans regularly.

Is talc the next Takata airbag? It very well could be in terms of its reach to product manufacturers, but there’s at least one key differentiator that companies need to be aware of. Talc doesn’t have a brand name like Takata, which means the reputational impact falls almost entirely on the manufacturers and producers that use the talc.