This article is written to meet the following sections of the Standards:

BRCGS Food Safety Issue 83.8 Control of non-conforming product
BRCGS Packaging Issue 65.7 Control of non-conforming product
BRCGS Agents & Brokers Issue 3
3.10 Control of non-conforming product
BRCGS Storage & Distribution Issue 43.9 Control of non-conforming product, damages and returns
15.14 Stock write-off
11.3.2, 11.3.3 Product returns
FSSC22000 Version 5.1ISO22000:2018 8.9.4 Handling of potentially unsafe products
IFS Food Version 75.10 Management of non-conformities and non-conforming products
SQF Edition 92.4.5 Non-conforming Materials and Product

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Looking to super-charge your continuous improvement process – then this pack is for you! Giving you simple, well-structured systems for:

  • Internal audits
  • GMP inspections
  • Non-conforming product
  • Returns
  • Stock write-off
  • Complaints
  • Non-conformances
  • Corrective action
  • Root cause analysis
  • Trending and review
Pack 3: Continuous Improvement eDocs

Introduction

When things go wrong, there needs to be a robust process in place to handle the product. In this article we look at how this should be done.

Non-conforming product

Non-conforming product is product (food and packaging), material or work-in-progress material which doesn’t meet the specification (this can also be known as out of specification product). It’s important that non-conforming product is controlled:

  • Because out of specification product must not reach the customer.
  • To ensure that non-conforming product doesn’t degrade while it’s being investigated.
  • To minimise the risk of more non-conforming product being produced.

Non-conforming product procedure

There must be a procedure for managing non-conforming product, which includes:

  • Clear guidance of what’s defined as non-conforming product.
  • How staff are trained, so that they can identify non-conforming product and how they should report it.
  • That records must be kept of all product placed on hold.
  • The product quantity and traceability codes.
  • The reason that the product is non-conforming.
  • How the product must be labelled, so it can be identified.
  • How product is held during storage, to prevent it from being used or released accidentally.
  • How corrective action should be taken.
  • What action is required, to allow an assessment of the product to be made.
  • How the product must be held, while an investigation is completed.
  • That the assessment must include risk assessment of the problem, to determine the required outcome.
  • How to record the investigation and the conclusion.
  • Who is responsible for making the final decision on what to do with the product.
  • How the decision should be recorded.
  • That the name of the person authorising the decision and date must be recorded.
  • That confirmation of what has happened to the product, including the disposal must be recorded.
  • That records must be kept of destruction, where a product is destroyed for product safety reasons.
  • That referral and approval of the brand owner must be completed and recorded, where needed.
  • That where subcontractors are used to carry out part or all of a product handling process, the requirements must be laid out in contract agreements and verified through supplier approval.

Hold log

A log of non-conforming products which are on hold, must be kept. This log must be routinely checked against the product held in stock – to confirm that it’s all present and correct. Where this isn’t the case, lost stock must be investigated to establish where it is.

Storage considerations

Chilled or frozen products must be kept in the appropriate temperature-controlled conditions, while issues are investigated. This is to ensure that the product doesn’t deteriorate further so that it can be reworked or sold to a different specification if the investigation determines that this is possible.

If product is non-conforming because it’s infested, then it must be stored in an area where there’s no risk of it contaminating other product.

Preventing accidental use

Ensuring that non-conforming product doesn’t reach the customer is extremely important, as it could be unsafe. If unsafe non-conforming product was to reach the customer or consumer, it could cause a recall.

Therefore, we must know where non-conforming product is at all times. And, it must be visually clear that it is non-conforming product, so it doesn’t get used by mistake.

This means there must be a process for handling non-conforming product – in the form of a quarantine or hold procedure.

This procedure must include physically isolating the product, ideally by moving it to an identified area. It must be clearly marked so that it cannot be confused with good product. The use of electronic inventory systems to ‘electronically hold’ the material is also an acceptable way of controlling the product.

Decision maker

Staff who are authorised and ultimately responsible for deciding what happens to non-conforming products must be experienced and technically competent. These staff are called Decision Makers, they must be identified and documented so it’s clear who they are.

Only Decision Makers have the authority to lift the hold notice or authorise the removal of product from the hold area.

Product outcome

All non-conforming products must be handled and disposed of in a way, which is relative to the problem. Unsafe product must be safely disposed of following legal and customer requirements.

Following assessment and investigation, the decision maker must decide what should be done with the product, which could be:

  • To reject it and dispose of it.
  • Accept it under a concession.
  • To rework into good product.
  • Use it under an alternative use.
  • Sell it under a lower grade specification.

 

Records must be kept of the decision, including:

  • The final decision on what to do with the product.
  • The name of the person authorising the decision (the Decision Maker) and the date.
  • What has happened to the product, including evidence of disposal – where it’s due to product safety.

Traded products

Where traded products are non-conforming the brand owner must be:

  • Contacted where the product is non-conforming, to allow the owner to investigate.
  • Consulted where non-conforming product is going to be released for sale.

Non-conformance

Non-conforming product must be treated as a non-conformance. This means that root cause analysis must be applied to determine preventative actions to prevent recurrence, when:

  • The non-conforming product is unsafe.
  • There is a trend in non-conforming product.
Pack 3: Continuous Improvement eDocs

Pack 3: Continuous Improvement eDocs

Looking to super-charge your continuous improvement process – then this pack is for you! Giving you simple, well-structured systems for:

  • Internal audits
  • GMP inspections
  • Non-conforming product
  • Returns
  • Stock write-off
  • Complaints
  • Non-conformances
  • Corrective action
  • Root cause analysis
  • Trending and review

Returns

product returns
Product can be returned because it’s non-conforming or because of logistical issues, such as order or delivery problems.

Returns policy

A policy must be in place, that defines what customer returns are accepted. It must list the products that can and can’t be returned, and any criteria that the returns must comply with.

The policy must be understood by those who handle returns, including drivers and relevant subcontractors.

The policy must be available to customers on request.

Returns procedure

Where returns are accepted, there must be a procedure which details what should happen to the product to determine if it’s non-conforming or good product. This may include:

  • Visual inspection.
  • Chemical, microbiological or allergen testing.
  • Quality attribute checks.

These acceptance requirements must be based on a risk assessment, so that they’re appropriate to each returned product.

The returns procedure must ensure that records include:

  • What product is returned, how much and the relevant traceability information.
  • Who has authorised the acceptance of the returns and any batches that are non-conforming.
  • What action is to be taken where a non-conformance has been identified.

Accepting returns

The procedure needs to take into account the risks of the product deteriorating, while it’s been out of the direct control of the site – e.g. temperature control.

Acceptance records must be kept.

Where products are stored while an investigation is completed, the product must be stored to minimise any further deterioration or contamination of other products.

Non-conformances

Where returns are due to non-conforming product being dispatched, a non-conformance must be raised.

Returns information must be reviewed, analysed and trended. Where trends are identified, a non-conformance must be raised and root cause analysis carried out, so preventive action can be applied.

Stock write-off

Stock write-offA stock write-off procedure must be in place for when product has to be written off because:

  • It’s got lost.
  • It’s becomes damaged.
  • It’s found to be non-conforming and has to be disposed of.

The procedure must ensure that customer requirements are met when their product has to be written off.

Where traded products are to be written off because the product is non-conforming, the brand owner must be consulted.

The procedure must detail:

  • Staff roles and responsibilities.
  • The communication process.
  • How customer must be consulted.
  • What records must be kept.

We hope you’ve found this mega-article on controlling non-conforming product useful, and if you have any comments or questions on this subject leave us a comment.

Pack 3: Continuous Improvement eDocs

Looking to super-charge your continuous improvement process – then this pack is for you! Giving you simple, well-structured systems for:

  • Internal audits
  • GMP inspections
  • Non-conforming product
  • Returns
  • Stock write-off
  • Complaints
  • Non-conformances
  • Corrective action
  • Root cause analysis
  • Trending and review
Pack 3: Continuous Improvement eDocs

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