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Shelf Life, Consequences of Labeling

food safety shelf life liability

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#1 sddingman

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Posted 18 March 2019 - 04:05 PM

Hello IFSQN

 

I am aware that there have been numerous posts on shelf life. This is not about the finer points of the types of shelf life, I would like to ask about potential consequences of shelf life decisions.

 

Our company manufactures a mineral food ingredient. We have assigned it a "best use by date" (BUBD) of 1 year. The product may lose some efficacy after one year, but not much and the loss is entirely dependent on storage conditions, and the product is a mineral based product so its not spoiling or becoming toxic. It should technically be effective long past 1 year, if stored properly, we just don't have supporting data. 

 

We, of course have, many customers coming back to us to issue a shelf life extension. We are uncomfortable with this decision because the product has been outside our chain of custody. However, some in our organization think we can test the product for efficacy for our customers and let them make the decision as to its usability. However, this does not appear to extend a food safety guarantee.

 

Others (including myself) are uncomfortable with this suggestion, since the test implies quality, but not safety. If a recall or auditable event were to occur with our customer, and this practice was examined though I am not sure what the consequences would be. I would almost rather offer a firm extension or simply state we do not recertify and we do not test.

 

On the other hand it's a BUBD, not an expiration date, so the liability seems less of a concern, but then why ask for an extension?

 

So my question: What do you think are the consequences of retesting but not recertifying a product with a best use by date? Are we opening ourselves up to more liability or does it just not matter since we have a BUBD?  What would a food safety auditor think if they saw a product past a BUBD but with a quality test? We would like to adopt best practice in this case.

 

Thanks in advance.



#2 pHruit

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Posted 18 March 2019 - 04:23 PM

Am I right in assuming "Best Use By" dates are intended as guidelines based on quality only, rather than limited by food safety factors?

In the UK we have "Use By" for foodstuffs with an absolute / food safety limit (e.g. cooked chilled meats), and "Best Before"/"Best Before End" (e.g. canned foods) for others where quality may decline by they can still be safely eaten/used beyond the quoted date - I'm guessing "Best Use By" is the US equivalent of the latter?

 

In which case, your initial shelf life isn't really about certifying food safety - you're effectively saying that the material is intrinsically safe due to formulation/packaging or similar, and that you warrant the quality/functionality for whatever your original shelf life is.

What specific attribute is it that you think limits the life, and is likely to change/decline?

With some products we advise that we can only consider giving a shelf life extension based on specific analytical results, and so we'd request that the customer sends a sample of their stock and pays whatever the cost of the analysis is. If one or more key components of the mineral blend may decline over time (e.g. naturally through oxidation reactions or similar) then this could be something that you'd need to consider.

For other simpler product, I often issue the opposite extension to the one you mention - I can readily confirm that a product will still be safe (but include a written disclaimer that this applies only to original unopened packs stored in correct conditions), but as the shelf life is limited by quality it is the responsibility of the customer to verify on-going suitability for their application(s). Generally we'd suggest that they perform an initial test (e.g. by taste panel, if organoleptic quality is the limiting factor) and then extend / test on a repeating cycle, with a guideline frequency that is appropriate based on the original life.

 

Obviously this means the customer is still doing most of the work and takes on the responsibility for making sure it is still suitable for their application - some would rather the supplier did everything, but in most cases they just want confirmation that it isn't a food safety matter so that they have this on record to show to auditors.
 



#3 EagleEye

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Posted 19 March 2019 - 05:11 AM

 

Obviously this means the customer is still doing most of the work and takes on the responsibility for making sure it is still suitable for their application - some would rather the supplier did everything, but in most cases they just want confirmation that it isn't a food safety matter so that they have this on record to show to auditors.
 

 

For this, as the supplier, when we provide this confirmation, should we have to provide the supporting documents also with which we ascertained its safety status or just a statement of confirmation on its overall safety? What would be the questions possibly an auditor would ask in such a case?

 

 



#4 pHruit

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Posted 19 March 2019 - 09:19 AM

Provision of "extra" information would be somewhat at your discretion. It may depend on practicality (our data set on product life monitoring is absolutely enormous) and business approach - in the old days I'd have shared almost anything a customer asked for as long as it didn't have a genuine potential impact on operational security/safety, but now we're part of a big corporate there is far more concern about intellectual property (much of it misplaced) so we wouldn't provide any specific data.

Generally I provide a statement making reference to a specific batch / batches so that the customer has something unequivocal for the auditor, and include a brief explanation of the rationale behind the statement and the basis on which the customer may make their own assessment of continued suitability- i.e. product/format is micro stable, limited by organoleptic durability, remains safe for use and is suitable as long as it's verified for the specific application(s) etc.

 

My experience has been that auditors really just want to see that there is a basis where a user has made an extension - personally I'd suggest a concession record with a copy of the statement that we provide, as this shows internal consideration of risk and the legitimacy of the approach is supported by us as the supplier.

The statement part may not actually be necessary if you have sufficient understanding of a given product / ingredient to justify what you're doing - when we have ingredients that go past BBE date I'd always prefer a statement or similar from our suppliers, but where needed I'll make an internal concession to extend an ingredient without this, as long as I can justify the basis for it.



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#5 EagleEye

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Posted 19 March 2019 - 09:33 AM

Hi pHruit,

A real enlightenment..

 

Thank you for your efforts.







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