Article 14 sets an early warning without undue delay and within 24 hours of awareness, followed by a notification without undue delay and within 72 hours. A reporting chain that works only during one team’s office hours is therefore fragile.
The escalation design should answer four questions at any time: who assesses the trigger, who can make the reportability decision, who can submit, and who confirms that the submission succeeded.
Name people and backups
Assign a primary and at least one backup for each role. Give the on-call responder a current contact path rather than a team name with no owner. Define how long an unanswered escalation waits before moving to the backup.
Keep legal and product-security judgment distinct, but do not make either a single point of failure. A temporary delegate should know the boundaries of their authority and when to escalate uncertainty.
Define the escalation envelope
For each role, record the contact order, response interval, authority limit, systems needed, and the condition that moves the case to the next person. The on-call incident manager should own the live deadline and be able to see whether trigger review, approval, submission, or completion evidence is blocking progress.
Prepare a minimum handoff packet that includes manufacturer and product identity, trigger analysis, awareness record, calculated limits, approved facts, unresolved questions, coordinating route, and evidence location. The backup should not have to search several private inboxes to understand the case.
Keep personal credentials personal. Continuity means separately governed access for each assigned person and an authorised way to transfer the case, not a shared password or an uncontrolled export.
Rehearse the difficult handoffs
Test a case that begins late on a Friday, crosses time zones, and contains incomplete product information. Verify that the team can find the coordinating-CSIRT route, access the reporting account, assemble the approved facts, and preserve submission evidence.
Add a second exercise in which the primary legal reviewer and reporter are both unavailable. Ask the backups to identify which decisions they may make, which require escalation, and how they keep the external clock visible while waiting. Stop the exercise before any real external action.
Measure the handoff by observable evidence: contact acknowledged, packet found, trigger decision located, approval path selected, draft prepared, and simulated filing evidence retained. A verbal assurance that somebody “would handle it” is not a result.
End the exercise with a named owner for every gap. The useful outcome is not a perfect tabletop score; it is a chain that remains accountable when the first people called are unavailable.
Continue this workflow with the reporting-access continuity plan and the readiness exercise.