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Juul Labs Youth Prevention

Design and implement a new compliance standard for submission to the FDA

Service Design

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Juul Labs Youth Prevention

Design and implement a new compliance standard for submission to the FDA

Service Design

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Juul Labs Youth Prevention

Design and implement a new compliance standard for submission to the FDA

Service Design

TEAM

30 Experts

30 Experts

Time

June - Nov 2019

June - Nov 2019

My role

Service Designer

Service Designer

KEY SKILLS

Analytics

Analytics

Analytics

Research

Research

Research

Service Design

Service Design

Service Design

Business Need

A new regulatory standard for submission to the FDA

In 2019, Juul was a $38bn company. Youth Prevention was top priority, both as a company mission and regulatory purposes for the FDA.


A process in restricting underage use was needed, in order for Juul to gain the permission from the public, to exist.

Background

A deadline was enforced

During this time, Juul’s CEO announced to the press - a $100mn investment in a new compliance standard, offering free Point-of-Sale systems to 800+ independent retailers in San Francisco.


The CEO mandated that we present 50 compliant retailers before the Nov. 3rd vote for Proposition C.

Retailer requirements needed to sell Juul products: properly age-gate & set purchase limitations.

Challenges

Retailers were unwilling to adopt this program

We had worked with two POS vendors to include age-gating and bulk purchase limitations on their checkout flow. That was easy and took a couple of days. The real challenge was getting retailers to adopt it.

Age Verification

This standard required retailers to scan a buyer's ID, taking the work out of the cashier calculating manually.

Age Verification

This standard required retailers to scan a buyer's ID, taking the work out of the cashier calculating manually.

Bulk Purchase Block

This standard required retailers to set a limit on a single buyer purchase to 1 device and 16 pods.

Bulk Purchase Block

This standard required retailers to set a limit on a single buyer purchase to 1 device and 16 pods.

I reached out to the 100 top retailers, no one said "yes."

These were the main pain points —

Resistance

Many top retailers simply did not want change.

"I've been checking ID manually, I'm fine! I have never been fined. I don't need a scanner."

Resistance

Many top retailers simply did not want change.

"I've been checking ID manually, I'm fine! I have never been fined. I don't need a scanner."

Resistance

Many top retailers simply did not want change.

"I've been checking ID manually, I'm fine! I have never been fined. I don't need a scanner."

Banking Conflicts

POS were tied to banks that processed the payments.

"I can't change my bank. I can't afford a new rate with higher transaciton fees."

Banking Conflicts

POS were tied to banks that processed the payments.

"I can't change my bank. I can't afford a new rate with higher transaciton fees."

Banking Conflicts

POS were tied to banks that processed the payments.

"I can't change my bank. I can't afford a new rate with higher transaciton fees."

Cash Only Businesses

Around 50% of the retailers used cash registers.

"I don't want this system, the FED can just come in and look at my transactions!"

Cash Only

Around 50% of the retailers used cash registers.

"I don't want this system, the FED can just come in and look at my transactions!"

Cash Only Businesses

Around 50% of the retailers used cash registers.

"I don't want this system, the FED can just come in and look at my transactions!"

Solution

Steps in getting to compliant

The process would follow in 3 main steps: Qualify + Recruit, Onbard + Install, and lastly, certification. During this time I was the single person talk to retailers and getting feedback, testing the process in the field and providing it back to the team. It was a group effort but there were a few key contributions that I made.

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I saved the company $10mn/yr

Leadership planned to hire 100 people to sell this program. I proved to them the existing sales team was sufficient.

I saved the company $10mn/yr

Leadership planned to hire 100 people to sell this program. I proved to them the existing sales team was sufficient.

I accelerated conversion by 26%

I focused on the 35% retailers that only need a software update, which only took 1 minute each to upgrade.

I accelerated conversion by 26%

I focused on the 35% retailers that only need a software update, which only took 1 minute each to upgrade.

I converted the first retailer

I convinced the previous President of the AAGA to adopt. Once he signed up, more retailers did too.

I converted the first retailer

I convinced the previous President of the AAGA to adopt. Once he signed up, more retailers did too.

I removed large bottlenecks

I pushed for installation to be done by the POS vendor, and removed the biggest bottleneck preventing scale.

I removed large bottlenecks

I pushed for installation to be done by the POS vendor, and removed the biggest bottleneck preventing scale.

Retailers were resistant, so I had to be strategic— this is how I secured the first conversion, then refined the process to speed up adoption -

I converted the first retailer

I needed to find a local influencer to establish trust. With some research I found the ex-President of the AAGA, I knew his son - who had a vape shop. Working that angle, he was obliged to adopt. Once he signed up, more retailers did too.

I converted the first retailer

I needed to find a local influencer to establish trust. With some research I found the ex-President of the AAGA, I knew his son - who had a vape shop. Working that angle, he was obliged to adopt. Once he signed up, more retailers did too.

I accelerated adoption by 26%

During qualification, I found that 35% of retailers only needed a software update, not a new system, making installation much faster. Prioritizing these retailers shaved off weeks and accelerated adoption by 26%, streamlining the process for quicker adoption.

I accelerated adoption by 26%

During qualification, I found that 35% of retailers only needed a software update, not a new system, making installation much faster. Prioritizing these retailers shaved off weeks and accelerated adoption by 26%, streamlining the process for quicker adoption.

As I refined the process, I identified and removed major bottlenecks, resulting in significant cost savings -

I removed large bottlenecks

During new POS system installs, I calculated on average a Juul employee spent anywhere between 4 to 21 days to install a new POS system. I pushed for installation to be done by the POS vendor and removed the biggest bottleneck preventing scale.

I removed large bottlenecks

During new POS system installs, I calculated on average a Juul employee spent anywhere between 4 to 21 days to install a new POS system. I pushed for installation to be done by the POS vendor and removed the biggest bottleneck preventing scale.

I saved the company $20mn/yr

Leadership planned to hire 100 people to sell this program. I proved to them the existing sales team was sufficient factoring the time of qualification to certification being significantly reduced with the knowledge I collected in the field.

I saved the company $20mn/yr

Leadership planned to hire 100 people to sell this program. I proved to them the existing sales team was sufficient factoring the time of qualification to certification being significantly reduced with the knowledge I collected in the field.

Given the political agenda, a major pain point was getting representation out to Government Officials and City Hearings. I helped the company mobilize retailers at the grass roots.

I mobilized retailers to meet with their District Supervisor

I convinced retailers to get involved politically to meet with District Supervisors as part of Anti-Ban efforts.

I mobilized retailers to meet with their District Supervisor

I convinced retailers to get involved politically to meet with District Supervisors as part of Anti-Ban efforts.

I convinced retailers to speak up for small business

I developed key relationships and galavanized them to speak up on behalf of the impact to small businesses.

I convinced retailers to speak up for small business

I developed key relationships and galavanized them to speak up on behalf of the impact to small businesses.

Managing stakeholders

A select group of experts were chosen

The CEO pulled in 30 experts from every department for quick execution. There were some loose levels, personnel were used interchangeably between workstreams. Everyone had decision making power.

The PMO (Strategy Execution Office)

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Leading cross-functionally was critical for success

I led cross-functionally across Government Affiars, Operations, Product, Sales, Public Relations, Corporate Strategy, Management Consultants, Political Consultants, and Media at any given time to achieve matters large and small.

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TESTING

Refining the process through iterating

Due to the time constraint and impactful nature of this feat, we had to be strategic.

Real Time Iteration

The team iterated real time based on feedback I received from retailers (aka customers). And worked to push through every obstacle.

Real Time Iteration

The team iterated real time based on feedback I received from retailers (aka customers). And worked to push through every obstacle.

Real Time Iteration

The team iterated real time based on feedback I received from retailers (aka customers). And worked to push through every obstacle.

Recognition of Design Execution

Leadership was impressed at our execution and promoted 6 of us into a steering committee for continuity of the program. I was one of them.

Recognition of Design Execution

Leadership was impressed at our execution and promoted 6 of us into a steering committee for continuity of the program. I was one of them.

Recognition of Design Execution

Leadership was impressed at our execution and promoted 6 of us into a steering committee for continuity of the program. I was one of them.

IMPACT

Seeing the results

The pilot study of the compliance program showed dramatic improvement in retailer compliance. It laid the ground work for Juul's compliance-driven mission, and was part of Juul's PMTA submission to the FDA.

For age-verification compliance, the overall failure rate fell from 36.8% to 0.2% after implementation.

-36.6%

For bulk-purchase compliance, the overall failure rate fell from 29.3% to 1.0% after implementation. 

-28.3%

Lessons

What I learned?

Putting people first in compliance design makes all the difference—and stakeholder alignment is critical for success. I also saw how an iterative approach allowed for real time adjustments that was not just effective but scalable. All in all, it was incredible to see that we made something seemingly impossible, possible.