Risk register · entry
Q3 · EngineeredMattel lead-paint toy recall
Mattel audited its Chinese factories. Nobody audited the paint supplier four tiers down.
Tightly coupled systems where one small fault cascades and takes down the whole machine.
Why this room
Mattel's control system was built around its contract manufacturers, whom it audited and certified, and it required those partners to buy paint from approved and certified suppliers. The control did not reach the paint itself once it entered the chain below the audited tier. One non-approved lead pigment therefore propagated through a compliant-looking vendor into finished goods, and because the products were certified as a system, the defect surfaced as a cascade of recalls across many models rather than as an isolated fault. This is q3: the coupling between audit scope and supply-chain depth was tight, and a single small input failure took the line down.
The record
- Mattel and Fisher-Price agreed on 5 June 2009 to pay a $2.3 million civil penalty for violating the federal lead paint ban, the highest CPSC penalty at that time for importation or distribution of a regulated product.certain
- CPSC alleged Mattel imported up to 900,000 non-compliant toys between September 2006 and August 2007, and Fisher-Price imported up to 1.1 million non-compliant toys between July 2006 and August 2007.certain
- About 95 Mattel and Fisher-Price toy models were determined in 2007 to have exceeded the federal limit of 0.06 percent lead by weight in paints or surface coatings, a limit in force since 1978.certain
- The 2 August 2007 recall covered about 967,000 Fisher-Price licensed character toys manufactured between 19 April and 6 July 2007, with no incidents or injuries reported.certain
- Mattel's own 2 August 2007 statement said the toys were made by a contract manufacturer in China using a non-approved paint pigment containing lead, and its quality chief stated: 'We require our manufacturing partners to use paint from approved and certified suppliers and have procedures in place to test and verify, but in this particular case our procedures were not followed.'certain
Sources
The book
This entry is one of 111 in the register. The full story, and what it cost the people who lived it, is in Risky Business by Claudia Zeisberger, David Munro and Joanna Reijgersberg-Siew.
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