Jump to content

  • Quick Navigation
Photo

Accepted process to "destroy" non-conforming product

Share this

  • You cannot start a new topic
  • Please log in to reply
9 replies to this topic

PropellerPete

    Grade - Active

  • IFSQN Associate
  • 16 posts
  • 1 thanks
2
Neutral

  • United States
    United States
  • Gender:Female
  • Location:Oregon

Posted 06 June 2018 - 04:15 PM

Good morning all,

 

I am in possession of RTE food that was made with an ingredient whose micro doesn't meet our max APC criteria and is considered unsafe and not to be sold. There is no kill-step to remedy this. I have a few hundred units of this, and I need to "destroy" it. I want to put it in our dumpster the day before the garbage company comes and call it good. Does anyone know if there is legal liability on the company, if we document(including photos) that we disposed of the product responsibly, if say, someone took one out of the garbage and ate it? I want to dispose of the product safely, but I don't necessarily want to set it on fire, ya know? Do you think my process sounds reasonable? TIA!!



Scampi

    Fellow

  • IFSQN Fellow
  • 5,444 posts
  • 1507 thanks
1,524
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 06 June 2018 - 04:39 PM

When i was in poultry, we had to "denature" condemned meat that had the appearance of edible product. We just had a charcoal based spray that makes raw poultry look a disgusting green/black colour. Birko company makes one just called Birko Black. It comes concentrated and you just mix with water and spray (it's non toxic, just really gross looking as a deterrent)

 

I don't know about the USA, but here the company could/would still be held liable if someone dumpster dove and got sick. I would err on the side of caution on this one

 

If you contact the garbage company and narrow down a pick up time, then you may be able to dispose directly into the truck/ or dumpster that is then immediately dumped and record all the times/weights etc 


Please stop referring to me as Sir/sirs


dfwdilemma

    Grade - Active

  • IFSQN Active
  • 16 posts
  • 3 thanks
0
Neutral

  • Earth
    Earth

Posted 18 June 2018 - 12:53 PM

There are denaturant dyes you can purchase to "dye". I think you would be liable. You can also call the trash service and request "proof of destruction". 



ffkmm

    Grade - AIFSQN

  • IFSQN Associate
  • 25 posts
  • 1 thanks
1
Neutral

  • United States
    United States
  • Gender:Female
  • Location:Arizona

Posted 26 March 2019 - 09:58 PM

I am on the same boat. But do you have to have a proof of destruction for all non-conforming product? IF the product is not labeled with any company identification how can they trace that product.



Tony-C

    Grade - FIFSQN

  • IFSQN Fellow
  • 4,223 posts
  • 1288 thanks
608
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:World
  • Interests:My main interests are sports particularly football, pool, scuba diving, skiing and ten pin bowling.

Posted 28 March 2019 - 06:27 AM

Hi PropellerPete,

 

I’m of the same view as Scampi and dfwdilemma. In dairy we used to put red dye in ‘pig milk’ so that it didn’t re-enter the human food chain. As well as disposing of the product adequately it clearly needs to be identified as condemned so additional labels as well.

 

SQF Requirements and Guidance:

2.4.5 Non-conforming Product or Equipment

What the SQF Code says

2.4.5.1 The responsibility and methods outlining how non-conforming product, raw material, ingredient, work-in- progress, packaging or equipment detected during receipt, storage, processing, handling or delivery is handled shall be documented and implemented. The methods applied shall ensure:

i. Non-conforming product is quarantined, identified, handled and disposed of in a manner that minimizes the risk of inadvertent use, improper use or risk to the integrity of finished product;

2.4.5 Implementation Guidance

What do I have to do?

The supplier must document the procedure that outlines how to label and identify products that are rejected or quarantined as a result of inspection, audit or process deviation. The supplier must describe how non-conforming product is isolated in order to avoid its re-use or shipment.

In circumstances where product is adulterated or condemned, the supplier must detail how the condemned product is identified and disposed of.

The means of identification of non-conforming product and equipment must be communicated to relevant staff. This can be a system of tags, signs, designated storage locations, system holds or other methods that meet the intent of this section.

The supplier is required to keep all records of the disposition of non-conforming product and equipment including product that is reworked, repackaged, condemned and/or disposed of.

 

I like your idea of taking photographic evidence of the disposal.

 

Kind regards,

 

Tony



tadelong

    Grade - MIFSQN

  • IFSQN Member
  • 89 posts
  • 12 thanks
13
Good

  • Canada
    Canada

Posted 29 March 2019 - 05:21 PM

I feel pretty lucky here as an egg farmer. We smash 'em.



Jpainter

    Grade - MIFSQN

  • IFSQN Member
  • 75 posts
  • 19 thanks
16
Good

  • United States
    United States

Posted 29 March 2019 - 06:19 PM

Whenever I send product to be destroyed, I always like to take pictures of the destruction process. For example, if choosing to denature, get a couple of pictures of the product with labels and pictures of the product with the denaturatent on it. In my last job, we sent everything to the landfill that needed to be destroyed. If you want to go this route, get pictures and be sure to save your landfill receipt as evidence of destruction as well. If there is a known issue or non-conformance that is known, I would always take the steps to show that it has been destroyed whether labeled or not. This will save you future headaches in case of a recall or questioning by a regulatory agency. 



KevinB

    Grade - MIFSQN

  • IFSQN Member
  • 53 posts
  • 9 thanks
5
Neutral

  • United States
    United States
  • Gender:Male
  • Location:Maine

Posted 29 March 2019 - 06:29 PM

Yes you can be held liable. You would want to make sure that no one can/would consume the product.One of the recommendations that I had from a federal inspector was to open the product and mix it with either a dye like others are suggesting or bleach. I am fortunate that we have an incinerating facility that will give us a certificate of destruction.  Any RTE product that needs to be destroyed is sent there and a copy of the certificate of destruction is kept on file and with the CAP.

 

ffkmm  If the product doesn't meet your standards and you want to dispose of it why wouldn't you do everything in your power to make sure that it did not get in to the food stream. As an example we had a grocery store chain that had to dispose of 1/2 a trailer of frozen turkeys (right before thanksgiving) because freezer unit on the storage trailer went down. They fixed the unit allowed the turkeys to re freeze and them threw them in the dumpster. Some one saw them throwing away frozen turkeys. He pulled them out of the dumpster and started to give them a way to people that needed them. 



Hank Major

    Grade - SIFSQN

  • IFSQN Senior
  • 317 posts
  • 101 thanks
33
Excellent

  • United States
    United States

Posted 29 March 2019 - 07:11 PM

You also must obliterate the labels.



majoy

    Grade - MIFSQN

  • IFSQN Member
  • 243 posts
  • 92 thanks
63
Excellent

  • Canada
    Canada
  • Gender:Female

Posted 05 April 2019 - 03:29 PM

Another option, If you are dealing with a private garbage company, you can let them know you need these items to be destroyed and they can issue a certificate of destruction and you keep this in your file - but this maybe an additional cost.


"Whatever you do, do it well..." - Walt Disney




Share this


Also tagged with one or more of these keywords: non-conforming, destroy, unsafe product

0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users