13 replies to this topic

[MsMars]

Looking for some input from the IFSQN community...

 

How does your company handle label updates? Does your company request updated specifications from suppliers on a regular basis, or is it outlined in your supplier agreement that they will provide updated specifications within a certain time frame after changes are made? What are the general expectations that everyone else has for supplier specification updates/label changes?

 

We do a little of both, and have recently sent out a letter to all of our suppliers requiring them to give us notification within a certain time frame when specifications/formulations are changed so that we have time to get our labels updated. However, I'm concerned with the enforceability of such an agreement as upper management tends to resist changing suppliers (as our letter threatens) unless it makes sense in $$ (full senior management commitment is an ongoing, separate issue). 

 

Also - how does everyone handle label change transitions in the production facility from old labels to new? Both USDA and FDA labels? Temporary approvals for old USDA labels are easy to come by, but what about FDA labels that have changed? 

 

Labeling is not technically in my job description and I am not well versed in it, but I seem to have a good chunk of the process placed in my lap lately. I just keep thinking that there has got to be a better, more straightforward way to handle all of this than what we are currently doing. A push or two in the right direction would be helpful! TIA

[Scampi]

MrsMars, you're receiving ingredients that are already blended?

[SQFconsultant]

We will be using an outside label consulting company for the new cheese company and have a requirement for an immediate contact from suppliers in the event of a formulation change. First the change must be approved by the company and then the information is transmitted to the label folks who make any needed adjustments on the labels, handle any needed submissions for approvals and also re program our label printer that is in the finishing area.

 

Yes, even consultants use consultants.

[MsMars]

MrsMars, you're receiving ingredients that are already blended?

 

Scampi - yes, for the most part. We receive RTE/RTC ingredients (for assembly of RTE and RTC items) but also dough ingredients (for manufacturing of raw dough which is later frozen).  

[Scampi]

Thanks MrsMars, I would follow Glenn's advice....all you can you do is communicate to the vendors and have them reply back in some format that they will comply with your request to be notified should their product formulation change.

 

Odds are, in order for a vendor to change the ingredient composition, there would either have to be A) a huge availability issue (like right now with the crazy prize of pure vanilla) or B) a strong customer demand for a new blend

 

Most likely they will have more than one source for their raw materials, but the actual composition of their finished good/your raw material will not change.

 

Label changes are HUGELY expensive and companies tend not to have to do that

 

If your supplier does notify you of a change, and your label would require changing to be accurate, you will have to put the finished good on hold, otherwise it is a false statement on the package regardless of whether or not it includes an allergen

[MsMars]

Odds are, in order for a vendor to change the ingredient composition, there would either have to be A) a huge availability issue (like right now with the crazy prize of pure vanilla) or B) a strong customer demand for a new blend

 

 

 

With the ban on PHOs here in the US as of late, we have had quite a few suppliers changing formulations. Some of our suppliers didn't notify us when they actually made the changes, a lot are smaller companies like us.  I feel like our R&D dept. (who is supposed to be in charge of labeling) knew about the PHO ban and could have been more proactive in communicating with the suppliers about all of that, but that is water under the bridge now. Hopefully now with the deadline for these changes approaching in 4 days these issues may slow down. However, we still have had suppliers making other random changes lately to reduce allergen declarations, nitrites, etc., sometimes notifying us and sometimes not.  I feel like that will be a trend for a while. 

 

 

We will be using an outside label consulting company for the new cheese company and have a requirement for an immediate contact from suppliers in the event of a formulation change. First the change must be approved by the company and then the information is transmitted to the label folks who make any needed adjustments on the labels, handle any needed submissions for approvals and also re program our label printer that is in the finishing area.

 

Yes, even consultants use consultants.

 

I've mentioned the use of a label consulting company a few times.  Maybe now that there are several of us that are completely overwhelmed with keeping up on all this, they will seriously consider it. Plus the fact that the contact person for all of our labeling who is supposed to have all of the answers on legislation and whatnot tends to circle back to me and others on questions about what is compliant would imply that some type of outside help is definitely warranted. 

[Scampi]

I agree MrsMars, the R&D department should be ahead of the curve on this

 

So what is your process when products arrive?  Are the ingredients verified against an approved list for that material?  

[MsMars]

No, we do not have enough warehouse staff to verify case labeling against material specifications upon receipt. They usually notice if a box or item has a drastic change, but they would not notice a minor change in ingredient declaration or allergen. I try and do random verifications of case labels vs. specifications when I can, but I'm only one person.  

[Scampi]

So out of curiosity, how do you discover there is a problem?  

 

What does the warehouse staff check (i understand both warehouse and QA are always tiny relatively speaking)

[MsMars]

It depends.  Sometimes I discover an issue when I do my random spot checks on case labels vs. specifications.  Sometimes it's discovered when I request supplier approval updates and current specifications are requested.  Our R&D sometimes discovers it if they are developing a new product and request specifications. 

[Scampi]

Are you SQF?  If so, how are you meeting 2.4.4?

 

This is what I would do in your situation (sorry if this isn't helpful) put ALL incoming materials on hold until they are verified as correct by someone who knows what they are looking for.

 

You've mentioned you're struggling with management, this may force them to belly up to the bar so to speak. 

 

Can you get production to verify the ingredients they are batching at the beginning of each batch?  You should not be the only person making sure things are correct

[MsMars]

Are you SQF?  If so, how are you meeting 2.4.4?

 

This is what I would do in your situation (sorry if this isn't helpful) put ALL incoming materials on hold until they are verified as correct by someone who knows what they are looking for.

 

You've mentioned you're struggling with management, this may force them to belly up to the bar so to speak. 

 

Can you get production to verify the ingredients they are batching at the beginning of each batch?  You should not be the only person making sure things are correct

 

I agree - I should not be the only one.  I wish it was as easy as me being able to put things on hold until they're verified! Surely there are other small companies out there with lack of adequate staff that have a way of handling this... anyone? Bueller?

 

Can you elaborate on how we aren't meeting 2.4.4 with regards to these issues?  I've been a little more concerned with meeting federal labeling compliance requirements. 

[Scampi]

Bueller  LOL

 

 

So 2.4.4. requires you to A) have approved suppliers that send you materials that meet an approved specification and that the suppliers are monitored.....so if no one is verifying receipt, your out of compliance

 

2.4.4.1 Raw materials, ingredients, packaging materials, and services that impact on finished product safety shall

meet the agreed specification (refer to 2.3.2) and be supplied by an approved supplier.

2.4.4.2 The receipt of raw materials, ingredients, and packaging materials received from non-approved suppliers

shall be acceptable only in an emergency situation, and provided they are inspected or analyzed before use.

2.4.4.3 The responsibility and procedure for selecting, evaluating, approving and monitoring an approved supplier

shall be documented and implemented.

 

I understand and agree that meeting fed labelling is of utmost importance, but because products are not being verified at receipt, and you know you have an ongoing issue(s) I would start by reviewing this section and your program and the 2 should meet in the middle and you should always be in compliance with the law

 

We are VERY small (less than 10 employees) but we still make sure that what arrives is what we asked for. 

 

Perhaps you can show upper management just how much a recall costs????  With luck, once they understand the cost, they will get on board to prevent it.  Hint: most small business cannot recover financially 

[Gerard H.]

Dear Ms Mars,

 

The best is to work with regularly updated supplier specifications. There is a bigger risk of changes, when the mixes aren't tailor-made for your company. These ones need to be updated more frequently. As soon as you receive the new specification, you compare it with the old version.

 

A second step is to keep an active relationship with your suppliers, to be informed of the latest developments.

 

There is also your internal recipe management to consider for the labeling.

 

Kind regards,

 

Gerard Heerkens