produced new bottles of product then withdrew numerous tasting samples that all passed our standards. At that point we wanted to act rather than wait for confirmation of the origin of the contamination. We knew that any definitive conclusion, if we ever got one, could take weeks or even months. We also wanted to replace bottles, not engage in any buyback activity, so our concern extended to whether we held adequate confidence in our new bottled product. We decided we were as certain as possible without a lab confirmation of the contamination. Every decision we made throughout this process we based upon incomplete information and inferences.

A VOLUNTARY RECALL Any voluntary recall is solely up to the manufacturer to perform. Neither the TTB nor the state gets involved. Fortunately, our distribution area was miniscule. By the following Tuesday we had visited every liquor store and had replaced every bottle in stock with new product. We had also visited every bar and restaurant that we knew featured our liquor. We realized there could be others that we were not aware of. Simultaneously we were working with our state agency to finalize details of our recall and produce our press release announcing it. The state director had the agency media agent at WSLCB contact us. He started the press release process by sending us samples of public notices. After we had a rough draft worked up, we sent it back to him for his input. We sent another copy to the head

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enforcement officer of the state to ensure that the details of our recall met state requirements. It was our responsibility to settle on the final wording and get it distributed. While we were solely responsible for the press release, their reviews were very helpful. They also provided a list of news outlets upon which we could base distribution of our public notice. As it turned out, the TTB informed us that the FDA had decided that there was probably no health hazard on the same day that we completed our tour of our distribution territory replacing all bottles in retail outlets with certified new bottles. The relief we felt upon hearing that our recall was apparently a Class I recall, meaning no known health impact, was very welcome. It would not have come nearly as soon if we had not promptly notified the TTB that we had a problem of unknown origin and unknown health consequence. We were still formulating our formal recall notice, and now had high confidence that the problem was limited to unpleasant product alone.

GOING PUBLIC We asked ourselves whether we should proceed with the public notice and consumer recall or not. Others questioned whether we wanted the adverse publicity. We decided to proceed. We did not want unidentified bars and restaurants, or any customer to open a bad bottle and think it fairly represented our product. We were certain that word of the recall would get out, and we wanted to provide the official word on what happened and what we did about it. Foremost, we felt that it was the responsible thing to do for

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