Your recall started in someone else’s factory

In the last sixty days, AVID Medical recalled 5,168 cardiovascular procedure kits. Three separate times. The reason in the FDA record is not about AVID. The kits contained Medline manifolds with particulate in the fluid path, and Medline had already recalled them. Medical Action Industries recalled 657 kits over the same part. Spectra Medical Devices recalled product because its contract manufacturer had been cited for sterility assurance.

None of those three firms made the defect. All three own the recall.

This is the part of the enforcement record that outsiders read wrong. They see a recall list and assume every line is a company that made something badly. A large share of the lines are companies that bought something badly, or bought from someone who was already in trouble and did not know it yet. The defect is upstream. The notification duty, the customer letters, the effectiveness checks, and the root cause that has to hold up are all downstream, sitting with whoever put their name on the box.

The firm that has to run the recall is often the one furthest from the thing that went wrong.

Which changes what help actually looks like. A firm in this position does not need someone to fix its production line, because its production line is fine. It needs someone who can rebuild a supplier file under deadline: what was received, what was inspected, what the incoming spec said, which lots went where, and why the same part will not come through the door again. That is a supplier-quality problem wearing a recall costume, and the people who are good at it are not the same people who are good at manufacturing remediation.

The other thing it changes is timing. When a component maker recalls a part, every firm that bought it is about to have the same week, and most of them do not know it yet. The upstream recall is public before the downstream ones exist. That gap is narrow, and it is visible in the data, which is the whole reason I watch this lane.

— Ken Callwood