Do I need a safety program? What’s a safety program?
If you’re currently a seller on Amazon.com, you may have at one time already received a Safety Notice from Amazon wherein you are informed of an “incident” of some sort. Your offer might have been removed completely, pending a response from you, or simply been disabled, pending your own confirmation of correct info and subsequent manual relisting. In either one of these situations, an investigation on your part is necessary. This is where a solid safety program comes into play: knowing what to do in the event of a safety incident, and better yet, heading one off before it ever happens.
If you’ve never asked yourself this question, do it now: “In what ways could my product fail, either due to integrity of the product itself or foreseeable misuse, that I should be aware of and control for?”
What’s Foreseeable Misuse?
Foreseeable misuse is anything that you can rest assured some customers will do. They will overload the garlic press and the pins will break and shrapnel will fly into the spaghetti sauce. They will overfill the French press with hot water and then the pressure from the steam and the plunger moving down will spray hot water and coffee grounds all over their face.
What are some ways that you know people will misuse the product you’re selling? Your first line of defense in any good safety program is right here. Be VERY obvious with your warnings not to overload, overfill, overuse, or overwhatever. Put it on the detail page, put it on the package, put it in your follow up emails: DO NOT OVERLOAD THE GARLIC PRESS! SHRAPNEL IN THE SPAGHETTI SAUCE!
OK so what is Unforeseeable Misuse?
Unforeseeable misuse is if someone smacks you over the head with the garlic press. You don’t have to worry about that one as much.
Outright Product Failure
Let’s say that one of the ways you’ve identified that your product can fail is at the hinges. It’s a foldable plastic step stool, and if too much weight is applied, it will bust. This causes scrapes on legs and cuts on hands from sharp plastic, and customer complaints.
Your first line of defense is to explain, as above with the garlic press, in no uncertain terms that the weight limit is XX lbs. Put it all over the place. This might be a case of foreseeable misuse, and as we know it’s very important to look out for these things.
But what if it is actual product failure? These people are meeting the weight requirements. They are not jumping on it, they are simply opening/closing/standing on it, and at some point the hinges fail. This is not misuse at all. It seems the hinges are a safety issue.
Your Safety Program Nuts and Bolts
As soon as a safety issue is identified, it is important that you remove the item from sale immediately. It does not matter if it is your best seller, it needs to come down. Return all product to you for inspection and root cause analysis. In fact, Amazon itself holds this idea in such high esteem that it gives anyone… any person employed at Amazon… the authority to remove any product from sale the moment a safety issue is identified. Do not sit on it, do not file a ticket to some other team, do not pass Go, take the product down now. This action is totally reversible, the product can be back online in no time, but to possess knowledge that a product is unsafe and to continue to sell it is a very bad thing indeed.
In a perfect world, you had your step stool tested for safety in a lab before it ever went on the shelves, and you’d have your test results available to send to Amazon should they ever ask for them. If you’ve already identified a safety issue but you do not possess these tests, it will be necessary to have testing performed before turning your listing back on. I would strongly advise against turning it back on without such tests, particularly because you’ve pinpointed the problem. Do you want to sell unsafe merchandise? No. That’s never going to end well. See above about Amazon’s immediate takedown rule. Liability is no joke.
If you’ve identified the problem yourself and taken the listing down on your own, you can do this testing “behind closed doors” to make sure all is on the up and up. If the step stool does not pass, do not relist until you’ve retooled the product and it passes muster.
If Amazon took your listing down as part of a safety investigation, you’ll have to supply them with acceptable testing before they’ll turn your listing back on. This becomes part of your “permanent record” in Amazon’s system, and the more safety incidents you have like this, the more scrutiny will be placed on you. If your seller account is suspended due to safety incidents and you have not done your due diligence, you have little chance of being reinstated.
Amazon takes liability issues very seriously, and so should you.
Your customers’ safety is of the utmost importance, and you should take a good hard look at your products for any ways that safety can be compromised. If you sell health supplements, you need a plan for ensuring expired product does not make it to customers. What about the bottles, are they sealed tight? How do you know, where is your analysis of the bottle’s seal? Will the product spoil if kept at high temperatures?
In developing your own safety program, be sure you are doing as many things as you can proactively: proper warnings on the detail page, packaging, etc. Appropriate testing to ensure the integrity of the product. Accurate description on the detail page, with product specs if necessary. Ask your customers if they like their product. Ask them what could be better. Read (and respond to) the product reviews on your listings. If you see a potential safety incident, reach out to the customer. Respond publicly with acknowledgement of their concerns and whatever you’re doing to address them.
If you find yourself already embroiled in a safety investigation with Amazon, cooperate fully. Provide all required testing, answer all the questions they have, as honestly as you can. If you can have the product returned to you, either by removal order or with assistance from Amazon, do it. Look at the product with your own eyes and try to see what happened.
In my time working on Amazon’s Product Safety team, very often the safety incidents were nothing too serious but still needed to be addressed. It was very rare that there was catastrophic product failure causing serious injury, or a product recall, but it did happen. I can assure you that any incidents you will experience in the future will be made much more painless by putting some thought into a safety program now. If you’re lost and have no idea where to start with this, please reach out so we can help you.