Two Recalls, Two Different Hazards: The Value of Non-Food HACCP

Two product recalls published by the Office for Product Safety and Standards on 16 September 2026 demonstrate why structured hazard analysis is valuable across non-food manufacturing.  The products and hazards were very different, but both cases concerned contamination that should be considered when evaluating materials, suppliers and manufacturing processes.

Two batches of a hand-wash refill were recalled after testing identified Pluralibacter gergoviae.

The microorganism may cause infection or adverse health effects, particularly among vulnerable users or people with a compromised skin barrier.

For manufacturers of water-based personal-care products, the recall highlights the importance of controls covering:

• Raw-material and process-water quality.
• Preservative effectiveness.
• Manufacturing and filling hygiene.
• Bulk-storage conditions and times.
• Microbiological testing and product release.
• Batch identification and traceability.
• Product recall controls

Read the hand-wash recall notice:

https://www.gov.uk/product-safety-alerts-reports-recalls/product-recall-baylis-and-harding-oud-cedar-and-amber-1l-hand-wash-refill-2609-0060

A children’s outdoor game was also recalled because the sand filling its bean bags may contain a small quantity of asbestos. Asbestos is prohibited because it presents a health risk even at low levels of exposure. The product was withdrawn from sale, and consumers were given specific instructions for containing and returning it safely.

This case illustrates why hazard analysis must consider what a raw material could contain—not simply its intended purpose. 

Relevant controls may include:

• Raw-material specifications.
• Identification of prohibited and restricted substances.
• Supplier approval and monitoring.
• Understanding requirements in the country of manufacture.
• Risk-based verification and testing.
• Material and finished-product traceability.

Read the game recall notice:

https://www.gov.uk/product-safety-alerts-reports-recalls/product-recall-smyths-toys-wooden-cornhole-board-with-bean-bags-2609-0108

HACCP is not a statutory requirement for every non-food product. However, its structured principles can help manufacturers identify potential hazards, establish preventive controls and verify that those controls remain effective.

These recalls demonstrate two distinctly different hazards:

1. A microbiological hazard identified in a formulated product.
2. A prohibited contaminant entering through a supplied raw material.

Finished-product testing remains valuable, but it cannot replace effective preventive controls across the supply chain and manufacturing process.

RI Training provides practical non-food HACCP training for people responsible for developing, implementing and reviewing hazard-control systems. Our programmes can be tailored to personal-care products, cosmetics, household cleaning products, car-care products, packaging and other non-food manufacturing sectors.