The safety of climbing equipment has never been better. The vast majority of modern climbing equipment is well-designed, rigorously assessed against industry standards and subject to robust quality management systems. On rare occasions equipment may fall short of these standards. Manufacturers have a range of options for dealing with this, depending on the cause and severity of the problem. This article explains the steps which can be taken to rectify issues with product safety. These problems could arise due to design, manufacture or quality assurance.
Product recalls, Product Safety Reports and Product Safety Alerts are issued by manufacturers when they have identified a potential safety or quality issue with one of their products. We’ll refer to them here as “Manufacturers’ Notices”, but these terms have specific legal meanings explained here.
Manufacturers’ Notices can apply to any consumer goods, from cars to tinned food. Here we’re going to explore how they apply to climbing, mountaineering and ski mountaineering equipment.
Personal Protective Equipment used in climbing and mountaineering is more likely to be subject to a Manufacturers’ Notice than other outdoor gear such as walking boots and waterproof jackets. This is because of the much higher rate of inspection, quality control and testing required to demonstrate compliance with standards, in line with the greater severity of consequences associated with failure.
How are problems identified?
Issues with a product may be identified by various means:
Production Quality Management System identifying a deviation from the design specification. This could include insufficient strength, sharp edges or incorrect function. They could be identified through inspections, and both non-destructive and destructive testing. The cause of faults may be changes in staffing, production facilities, insufficient maintenance of production machinery and incorrect configuration of new production machinery. Example
Retailers may report quality concerns to manufacturers. These may be identified when transferring stock to the shop floor. This information would typically be forwarded to the manufacturer’s distributor. Example
Failures in service, or during end user maintenance. These could occur as a result of equipment failure, inspection of equipment, or while handling equipment during use and could also arise from accident reporting. Reports of product defects (but not the result of simple wear and tear) should be made directly to the manufacturer’s UK distributor and also passed to the BMC. Example
Failure to function as expected. Reports should be made to the manufacturer’s UK distributor and also passed to the BMC. Example
Product Recalls are typically used where there is evidence of a manufacturing or design fault associated with a product. The product will usually be returned to the UK distributor for one of three outcomes:
Where the recall applies only to certain batches of a product, or where the fault may be easily identified by the end user a Request for Inspection may be issued.
Where the recall applies to all units of a model, and the fault can not be easily identified by the end user, the manufacturer may instead initiate a recall of all products which could be affected.
Manufacturers use a variety of different batch identification formats. Some will indicate batches by year, typically as 4 digits, some by month and year while others define batches as alphanumeric codes, or using serial numbers.
Product Safety Reports
Product Safety Reports are an alternative to a recall. They may clarify a description of how the product is used, or remove an intended use from the instructions entirely. It may also exclude certain modes of use not considered in the design process, for instance if the manufacturer finds that the product is used for an activity which was not considered during the design process.
Product Safety Alerts
Product Safety Alerts affect a class of product which has been identified to pose a risk of serious injury or death that has not been previously identified, such that immediate steps are required from businesses, authorities and possibly consumers.
Details of a company’s legal obligations regarding Manufacturers’ Notices are provided here.
Due to the international nature of equipment manufacturers and the different legal frameworks in their home countries, the language describing Manufacturers’ Notices may vary between manufacturers. The notice will generally provide a clear indication of action required by users of the product, and it is recommended that these actions are followed.
UKCA/ CE Marking
Readers will likely be familiar with the system of CE Marking which was in place prior to Brexit. This required many products sold within the EU to be provided with a CE Mark which is issued by a manufacturer, on confirmation that the product is compliant with the necessary regulations and standards for sale in the EU.
Following Brexit this has now been replaced with the UKCA Mark which functions on the same principle for England, Scotland and Wales. Northern Ireland continues to use CE Marks due to its special status in the Brexit agreement.
From 1st January 2021, products previously sold under a CE Mark were intended to be provided with a UKCA Mark. However, there are several grace periods associated with its introduction:
After 31st December 2022 products may no longer be provided with only a CE Mark, a UKCA Mark must be provided in addition, or in place of the CE Mark.
Until 31st December 2023 products may be provided with a UKCA Mark on their packaging, or associated documentation while having a CE mark on the product itself. This allows previously manufactured goods to work their way through the supply chain to end users.
From 1st January 2024 all goods to which the UKCA Mark is relevant should have it indelibly applied somewhere on the product, unless it is not possible to do so, in this case it must be applied on the product’s packaging or associated documentation.
There is a wealth of information available concerning recalls. Here are a few reliable sources.
https://www.theuiaa.org/safety/safety-standards/recalls/ - This is the most comprehensive source of collated recall information.
https://outdoorsafety.rocks/recall-history/ - Covers a range of manufacturers, includes email notifications of product recalls. (Last updated 2021)
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