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The Food Scientist

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Posted 07 August 2019 - 01:42 PM

Hello everyone!

 

I have a question. We are a spice/seasoning company that packages and repackages products. I have been only hired for a few months and I noticed they had no scale calibration last year done by a third party. We got an email saying this year's due date. Top management were like we are not required to calibrate our scales (they say USDA told them so), They then tell me oh just these big scales and thats it, not the small ones we weigh product on. Question is is there a requirement where we have to gt a third party annually to calibrate? USDA/FDA? Suggestions? Thank you!


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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Posted 07 August 2019 - 01:59 PM

I have always been told that it depends on many factors. Does the scale manufacturer have a recommended calibration schedule? Also, how often and the environment will have an impact as well. We are a contract manufacturer - mainly - and we have a 3rd party calibrate annually. If you are finding inconsistencies with your scale then I would recommend maybe bi-annually or quarterly? 



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Posted 07 August 2019 - 02:03 PM

The small ones where you weight product on are probably the ones I would be focusing on the most actually. Those are the ones were fluctuations tend to be more noticeable (especially if you are testing or using these scales for weights in a retail setting). We calibrated all of our scales once a year, to satisfy BRC requirements. Employees using scales checked them everyday as verification, and QA checked all the scales in the plant each quarter for additional verification. 

 

I would not suggest not having scales at least calibrated annually. I don't know of any FDA requirements for food regarding this calibration, but I know there is a clause in the CFR for medical devices regarding calibration being done routinely. Can you find operating manuals for your scales? Usually, the manuals will give instructions on suggested calibrations. You might be able to use this information to assess your calibration frequency.



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The Food Scientist

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Posted 07 August 2019 - 02:15 PM

We are SQF Quality Code certified. I remember the auditor said you don't need to calibrate your scales if you verify them everyday and they seem to be working.... I am not sure though..


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


AW1488

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Posted 07 August 2019 - 02:21 PM

Wow shocked your auditor said that.  Also I noticed your company said "USDA" told us we didn't have to.  Are you under USDA or FDA? (I also work for a spice company that caters towards the meet industry.  I get USDA/FDA arguments all the time)  FDA establishes net weight content minimums for all packaging and you need to verify you are meeting those.  Or else the FDA could issue your company fines.  So you want to make sure the scales are calibrated properly.



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Posted 07 August 2019 - 02:23 PM

Wow shocked your auditor said that.  Also I noticed your company said "USDA" told us we didn't have to.  Are you under USDA or FDA? (I also work for a spice company that caters towards the meet industry.  I get USDA/FDA arguments all the time)  FDA establishes net weight content minimums for all packaging and you need to verify you are meeting those.  Or else the FDA could issue your company fines.  So you want to make sure the scales are calibrated properly.

 

Oops sorry for the error, I meant Dept. of Agriculture. (State)..


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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Posted 07 August 2019 - 04:57 PM

We are SQF Quality Code certified. I remember the auditor said you don't need to calibrate your scales if you verify them everyday and they seem to be working.... I am not sure though..

 I'm not super familiar with SQF, but I thought BRC and SQF would be aligned enough to offer similar standards for calibration. Pretty much all of the auditors I've ever dealt with (GFSI or customer based) wanted to see annual calibration records OR calibration records based on risk assessment where needed. Therefore, annual scale calibration was the norm for us.



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Posted 07 August 2019 - 06:28 PM

In SQF 8.0 11.2.11 it talks about calibration in general and says that calibrations should be performed according to regulatory requirements and/or to equipment manufacturers recommended schedule. 



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Posted 07 August 2019 - 07:26 PM

A thought to bring to your top management. Food labels are required to be accurate including the amount of product you say is in the package. So if you don't calibrate your scales, how would you know you are providing enough product in your package.  Companies have been sued in the past for not having enough product in packages. The lawyer fees would most likely cost more than what it would cost to calibrate a scale. If they tell you small companies don't get sued - that would be false. I've seen it happen, it just doesn't make the news.



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Posted 07 August 2019 - 07:55 PM

I agree with you all, the thing is I needed a proper discussion to convince top management! If it were all up to me I'd calibrate those scales quarterly :) Much appreciated responses from you all!


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


SQFconsultant

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Posted 07 August 2019 - 08:46 PM

As an Auditor I always asked for proof of calibration for all scales - now, this could come in the of "official" documents such as state or county requirements (I remember Cook County, IL had this requirement that every year a specific company did all the calibrations and issued certificates) as as documented in-house calibration records - all I was interested in was proof.

 

Auditors should keep their mouths shut when it comes to making statements - always follow your GFSI Scheme, county, state, province, etc requirements and have proof of calibrations - there is no fall back to say that so and so told you verbally that you did not have to do so. In my eyes as an Auditor if you can not come up with either something in writting that you don't have to do this or records or certificates that you do it's the same as not being done.

 

As Dick Fisher from my Howard Johnson and Howard Johnson's franchise inspection days said - Verbal Don't Go!

 

Also, if TOP management told you this - they need to back their mouths up with documented proof - you don't want to get hung out to dry.


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Posted 08 August 2019 - 08:19 AM

A thought to bring to your top management. Food labels are required to be accurate including the amount of product you say is in the package. So if you don't calibrate your scales, how would you know you are providing enough product in your package.  Companies have been sued in the past for not having enough product in packages. The lawyer fees would most likely cost more than what it would cost to calibrate a scale. If they tell you small companies don't get sued - that would be false. I've seen it happen, it just doesn't make the news.

 

Obviously the members of this forum are inherently more concerned about the regulatory compliance end of things, but an alternative take on this for those struggling to convince upper management to cough up: If the scales aren't calibrated, how do they know they're not giving extra product away for free? ;)



The Food Scientist

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Posted 08 August 2019 - 12:30 PM

Obviously the members of this forum are inherently more concerned about the regulatory compliance end of things, but an alternative take on this for those struggling to convince upper management to cough up: If the scales aren't calibrated, how do they know they're not giving extra product away for free? ;)

 

Thank you! That was my discussion actually. We had the dept. of Ag visit us a few months ago to verify some product weights and they found out we are giving away free product. Top management did not seem to care though... I guess its cheaper than calibrating scales? But in some instances we are NOT adhering to net weight on the label and that is where the issue is! 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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Posted 08 August 2019 - 01:52 PM

Just another option, you can have the test weights, have it calibrated by third party every year and use these test weights to verify your weighing scales. This is a cheaper option instead of sending all your weighing scales for calibration every year.


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


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Posted 08 August 2019 - 01:54 PM

Now I believe we do have the test weights, About like 5 of them, so I can get those calibrated instead? Yes that is easier!


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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Posted 08 August 2019 - 02:15 PM

Just another option, you can have the test weights, have it calibrated by third party every year and use these test weights to verify your weighing scales. This is a cheaper option instead of sending all your weighing scales for calibration every year.

 

This is what I do, for the small scales at least - for the large pallet floor scales we have a company come on site. 



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Posted 08 August 2019 - 02:26 PM

Now I believe we do have the test weights, About like 5 of them, so I can get those calibrated instead? Yes that is easier!

 

Yes, this is acceptable - my auditors have not said anything about this practice.

 

So make sure you calibrate the test weights thru 3rd party, then when you do the verification of your scales, make sure you inspect the test weights for any scratches, dirts etc. and have it documented on your checklist.


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Posted 08 August 2019 - 02:58 PM

This is what I do, for the small scales at least - for the large pallet floor scales we have a company come on site. 

Might be worth asking them how much extra to have the small ones done while they're there - we've found that the added cost of a few small scales on top of the more numerous larger ones was pretty insignificant so not really any reason to not get them done.

And for those of you in the UK, it's usually worth checking with your local Trading Standards department on testing for check weights as they are usually very competitive on price, and few pieces of paper stand up to a regulator's queries better than a calibration cert from their own metrology service ;)



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Posted 08 August 2019 - 03:04 PM

Just another option, you can have the test weights, have it calibrated by third party every year and use these test weights to verify your weighing scales. This is a cheaper option instead of sending all your weighing scales for calibration every year.

 

We had an external company come on site and calibrate ALL the scales. Floor scales, analytical scales, and anything in between was calibrated by the external party. The only time we ever sent out a weighing scale was if it was a small analytical one that needed repair. Otherwise, they did all the work in-house. I can't imagine sending weighing scales out for calibration.

 

We also had NIST-certified calibration weights for our internal scale verifications. We did send the calibration weights out annually to be re-certified, and if they were damaged, we bought new ones to replace the old. Be sure to have a backup set of weights to use while you send out your others for re-certification. Also, be sure to pay attention to the class of the weights as well. Make sure that the class of the weights matches your needs. You want more accurate weights for intricate testing, but can use a mid-range class for something like floor scales.



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Posted 09 August 2019 - 05:42 AM

Might be worth asking them how much extra to have the small ones done while they're there - we've found that the added cost of a few small scales on top of the more numerous larger ones was pretty insignificant so not really any reason to not get them done.

And for those of you in the UK, it's usually worth checking with your local Trading Standards department on testing for check weights as they are usually very competitive on price, and few pieces of paper stand up to a regulator's queries better than a calibration cert from their own metrology service ;)

 

A nice idea, though when we have a customer requiring scales be tested daily (yes I know :headhurts: ) we need the calibration weights anyway. Also I would be surprised if any of the small weights even lasted for a whole year, what the operatives must do to them I cannot fathom



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Posted 09 August 2019 - 05:59 AM

In India, we will get all the weighing balances and standard bullion weights verified and stamped by the Legal Metrology Dept (Govt.of India) annually.

And also by a NABL accredited calibration laboratory annually. Daily verification inhouse.



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Posted 09 August 2019 - 08:12 AM

A nice idea, though when we have a customer requiring scales be tested daily (yes I know :headhurts: ) we need the calibration weights anyway. Also I would be surprised if any of the small weights even lasted for a whole year, what the operatives must do to them I cannot fathom

 

We also use weights for checking daily - doesn't take long, and if nothing else its a useful check that someone hasn't dropped the scales or done something else daft with them (put them on the floor and then accidentally hit them with a forklift, for example!) that has thrown their calibration out...



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Posted 14 August 2019 - 12:48 PM

We use a 3rd party to check our temperature measuring devices and our scales but we do our thickness gauges in-house with certified standards. I am looking into buying certified weights to verify accuracy of the scales we have checked. Incidentally the meaning of "Calibration" seems to be a bit fuzzy. I used to think it is the adjustment of a measuring device, which might be done after calibration, but it's just a comparison to a standard. It would seem to defeat the purpose of paying for a certified standard if you had to have that calibrated annually. Just trading one for the other.



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Posted 14 August 2019 - 01:58 PM

Yes, this is acceptable - my auditors have not said anything about this practice.

 

So make sure you calibrate the test weights thru 3rd party, then when you do the verification of your scales, make sure you inspect the test weights for any scratches, dirts etc. and have it documented on your checklist.

We get our scales calibrated once a year for our cut and wrap room,  but we also use a test weight as part of our daily pre-op checklist.  Make sure to get a good weight that comes with a traceable cert. 



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Posted 04 January 2021 - 07:47 PM

TimG - I will definitely look into what you said. and i have contacted our third party to see if it does.

 

Scampi - that's really interesting to know about the scales used for batching up because they make up about 50% of our scales, so if then are not required to be certified annually that would definitely save us some money. 

 

We currently have the one certified weight and its pricey to send it annually. so I definitely agree with you there. if its not required by some governing body that would be great.  

 

Thank you both so much! 





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