4. Incident management
Management of non-conforming product
Out of specification product, returns and stock write-off.
This article is written to meet the following sections of the Standards:
| BRCGS Food Safety Issue 9 | 3.8.1 Management of non-conforming product |
| BRCGS Packaging Issue 6 | 5.7.1, 5.7.2 Management of non-conforming product |
| BRCGS Agents & Brokers Issue 3 |
3.10.1 Management of non-conforming product |
| BRCGS Storage & Distribution Issue 4 | 3.9.1, 3.9.2, 3.9.3 Management of non-conforming product, damages and returns |
| FSSC22000 Version 5.1 | ISO22000:2018 8.9.4 Handling of potentially unsafe products |
| IFS Food Version 7 | 5.10 Management of non-conformities and non-conforming products |
| SQF Edition 9 | 2.4.5 Non-conforming Materials and Product |
The requirements
Non-conforming product procedure
There must be a procedure for managing non-conforming products, which includes:
- Setting clear guidance of what is defined as non-conforming product.
- Details of how staff are trained so that they can identify non-conforming product and how they should report it.
- Records of all products placed on hold.
- Details of 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.
- Corrective action taken.
- Action required to allow an assessment of the product to be made.
- How the product must be held while an investigation is completed.
- Recording of 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.
- Recording of the name of the person authorising the decision and date.
- Confirmation of what has happened to the product, including confirmation of disposal where necessary.
- Records of destruction where a product is destroyed for product safety reasons.
- Referral and approval of the brand owner where needed.
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 products which are on hold must be kept. This log must be routinely checked against the product held in stock, to confirm that it is all present and correct. Where this is not the case, lost stock must be investigated to establish where it is.
Storage considerations
Chilled or frozen products shall be held within the appropriate temperature controlled area while issues are investigated.
Infested product needs to be held in an area where there is no risk of contaminating other product.
Preventing accidental use
Ideally, the product must be physically isolated by moving it to an identified area and clearly marked so that it cannot be confused with good product.
The use of electronic inventory systems to ‘electronically hold’ the material is also acceptable.
Decision maker
Staff who are authorised and ultimately responsible for deciding what happens to non-conforming products must be experienced and technically competent.
Only a limited number of personnel must have the authority to lift the hold notice or remove product from the hold area.
Product outcome
All non-conforming products must be handled and disposed of according to the nature of the problem. Unsafe product must be safely disposed of in accordance with any legal or customer requirements, and must not be allowed to enter the market.
Following assessment and investigation, the decision maker will decide what should be done with the product, which could be:
- To reject and dispose.
- Accept by concession.
- Rework.
- To alternative use.
- Sold as a substandard product.
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 and date.
- Confirmation of what has happened to the product, including evidence of disposal where product safety is at risk.
Product returns
Return of product to site must be managed through a procedure, which defines the process and the responsibilities.
Traded products
Where traded products are non-conforming the brand owner must be:
- Contacted where the product is non-conforming, to allow them to investigate.
- Consulted where non-conforming product is going to be released for sale.
Non-conformance
Root cause analysis shall be used to determine preventative actions to avoid recurrence, where:
- Unsafe non-conforming product has been identified.
- There is a trend in non-conforming product.
BRCGS Food Safety Issue 9
There’s an additional requirement to include management of returned product into the procedure. However, this was already in the main part of the clause.
When product is returned there must be a pre-thought-out process for how that product is managed. This process must now be detailed in your non-conforming product procedure.
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