When does non-conforming product become an incident?
GFSI recognised schemes all require a system for handling non-conforming product and a system for handling incidents. But when does non-conforming product become an incident? It’s important to be clear about the distinction between the two, so it’s clear when the incident system should be applied in any situation. Let’s go through some definitions of non-conforming product and incidents, to understand what the standards say…
BRC does not provide a definition of non-conforming product as such, but it does provide a definition for a non-conformity as:
“The non-fulfilment of a specified product safety, legal or quality requirement or a specified system requirement.”
We can use this definition to create a definition of non-conforming product as “The non-fulfilment of a product safety, legal or quality specification requirement.” Therefore, any product that does not meet specification. The BRC define an incident as:
“An event that has occurred that may result in the production or supply of unsafe, illegal or non-conforming products.”
However, we know that there are many events that may cause non-conforming product, but we wouldn’t handle them all as incidents – for example, fluctuations in the production process. So, there must be a difference between non-conforming product and non-conforming product that should be handled as an incident.
We can see from the definitions that the BRC do not make a distinction between non-conforming product and non-conforming product produced as part of an incident. Therefore, it could be presumed that the BRC would expect the production of any non-conforming product to be handled as an incident. This is clearly impractical and would not add value…
For example, it is expected that the quality of the product may vary during a production run, and at times, the product may go out of specification. Quality checks carried out on the line should pick up this issue and bring the product back into specification. Any product that is produced, which does not meet specification, would be handled following the non-conforming product procedure – this may include putting the product to waste. It would be impractical to handle each of these instances as an incident and follow the incident management process.
However, when a contamination problem produces non-conforming product, depending on the contamination, you may expect this to be handled as an incident, in every instance. Therefore, a distinction is required between product that is just non-conforming and product that is classed as an incident. The incident process is designed to pick out non-conforming product that needs to be withdrawn or recalled, therefore there should be a system for highlighting when this is the case.
The SQF standard and the IFS standard do not provide definitions of incidents or non-conforming products, although the standards do require management of both.
The GFSI guidance document (for version 6.3) provides a definition of incident management which is:
“a process of identifying and managing any event where, based on the information available, there are concerns about threats to the food safety of product that could require intervention to protect consumers interests, such as Isolation and removal from the supply chain.”
Therefore, GFSI specifically class only food safety non-conforming product, as an incident. The GFSI do not provide a definition for non-conforming product, but it is part of the benchmarking standard to have a system which manages non-conforming materials. The GFSI clearly makes a distinction between product that would just be classed as non-conforming (non-food safety related issues) and product that would be classed as an incident (food safety non-conforming product).
We could use this theory:
Non-conforming product, handled through the non-conforming product system = product which does not meet specification due to quality or legal reasons.
Non-conforming product, handled through the non-conforming product AND the incident system = non-conforming product which does not meet specification as it is unsafe.
However, there is one problem with this – there may be instances in which product would be recalled, or most likely withdrawn from sale due to quality or legal issues. For example, the horse meat scandal was not a food safety issue, however, it would be expected that any product affected by this issue would be recalled. It is probable that when version 7 of the GFSI standard is released, the definition of an incident will be widened, given the lessons learnt from the horse meat scandal.
Many retailers will also withdraw product from sale if they feel that it is not of the required quality. Or if a product has been contaminated, even if it does not pose a risk to food safety, it may be recalled or withdrawn from sale to protect the brand. This means there are instances where a non-conforming product, must be escalated and handled as an incident. Having clarity around when this happens is key, to be able to train this out to on-site personnel.
For me, there is a clear distinction…
- Any product that is produced and is picked up as non-conforming on line at the point at which it is being produced (i.e. in real time) is classed as non-conforming product. If this product can be contained and the issue corrected – there and then, it is handled only as non-conforming product. The key point being, that there is no risk of the non-conforming product being dispatched.
- If the issue is not picked up on line during production, and is found at any later time – it must be handled as an incident.
- If the issue is picked up on the line, but product has already been packed (i.e. it is no longer in production) – it must be handled as an incident.
- If any non-conforming product is put into stock, or dispatched from site – it must be handled as an incident.
You could also think of this a different way:
- An issue picked up using on-line systems, contained and corrected immediately on-line = non-conforming product
- Any issue which is not picked up by the current systems and requires action to prevent customer impact = an incident.