Label Accountability
Our Silliker auditor says labels that were made for finished products were not all accounted for after completion of that production run. I'm stuck on the easiest way to account for labels after production run. We are a small company and do numerous products that are labeled with mostly labels we print ourselves. Our warehouse attendants prints labels when the orders are started and it can take several days to complete the order. Most orders have numerous products on them also. Any suggestions??
Not having control/accountability for the labels you're printing brings into question track and trace effectiveness, proper labeling procedures, etc. If you can't account for all labels that are printed, how can you verify that compliance to all regulations is adhered to. Unfortunately, with the size and diversity of your operation (because we are the same), the tighter control you will have to ensure.
I have a very generic form for any staff needing labels to fill out so I can track the amount that are going out vs. how many are being applied. Coupled with that, only select staff are able to print labels. You could incorporate a label review process in with this as well.
We do have a label review policy. What information would be needed on the form? Would this be enough?
Company Name
Product
Container Size
Amount of Labels Printed
Amount of labels Applied to Packaging
Amount of labels destroyed
Sign of of person applying labels
Below is the copied text of the request form we use. We've got a separate form for waste/scrap to track that as a KPI.
This could be integrated into your label review policy (we do a check for accuracy once per production lot).
You could ascertain how many labels were applied just by subtracting the amount of labels destroyed from the amount printed so I wouldn't feel a need to include that.
My next thought, as an auditor, would be to investigate what the process is to destroy a label. It could be just as easy as including a note in your labeling/label review policy as to how you denature them (ie paper shredder). I got into it one day with a USDA inspector about how it wasn't sufficient in her eyes to throw them in the garbage. As if burglars were going to dumpster dive and apply our labels to other products... you never know I guess.
Label Requests
Today’s Date:
Box Label or Sleeve Label: Circle one
Meal (IFD #, product code, etc.):
Quantity:
Best By/Sell By Date and Lot #:
(QA USE ONLY) Printed: Y / N
In past companies where retail labeling and in once case USDA were involved, tremendous care was taken. Since our labels came in already printed, there was a label check to ensure there were no changes. Any labels not going to be used were shredded and labels were handed out from a secure cage and tracked carefully. If 500 units were made then form needed to track how many went on product, how many were unusable and how many were returned to the cage. Labels were tracked like hundred dollar bills.