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Accidental Adulteration - Qualifications and Corrective Actions

adulteration corrective action

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#1 QC in NC

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Posted 26 September 2019 - 06:44 PM

Good Afternoon All, 

 

I am in charge of Food Safety and Quality at a beverage manufacturing facility. I am looking for some guidance surrounding the topics of adulteration and food fraud. We are certified under SQF food safety and quality. I am more familiar with the term adulteration but seems like SQF groups adulteration and mislabeling under food fraud. I assume this takes into account intentional as well as accidental adulteration.

 

We have a regular practice of taking finished product from bottles with quality defects and injecting product back into active finished product tanks while we are still in the filling/packaging process. The practice is to only inject the same product and lot# into the corresponding active tank. A mistake was made and one product was accidentally injected into the wrong tank. Similar product but completely different ingredients/flavors (one mango the other peach). Even though the volume injected into the tank accounted for 0.26% of the total tank volume, management made the decision to dump the tank, based on my recommendation that to move forward with the tank would involve knowingly mislabeling finished product. To me this was a black and white issue and dumping was the only option, as we had to make a quick decision as our tank capacity is tight. 

 

I am searching for any information from FDA or the like that would support this not being as black and white as I initially thought. We are looking at how to handle this issue if it ever happens again and I would like more information to support my rationale one way or the other. Is there some volume% under which this would not have been necessary? The issue did not involve any of the big 8 allergens, and it's possible to do the math and make the case that even someone with a rare allergy (i.e. peach allergy) would not likely experience due to low ppm/ppb of that specific flavor. Assuming the product would have been safe for consumers, did we make the right decision to dump? Does it come down to business ethics and responsibility? I would hate to find out that this is common in the food industry as it would make me question every thing I purchase.

 

Any information or guidance would be much appreciated. This is my first post to the forum, though I have been using this as my go-to information source for over a year now. Thanks in advance!!!



#2 SQFconsultant

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Posted 26 September 2019 - 08:17 PM

HI and first of all welcome to the forums!

 

This does not fall under Food Fraud.

 

It is simply an error and the corrective action was to dump it.

 

Frankly, it is unfortunately that you were tight on space, because I think a peach/mango mix would be rather good and a new flavor combo could have been created out of this, but alas it went down the drain.


Warm regards,
 
 
Glenn Oster
 
 
Glenn Oster Consulting / 800-793-7092 / Serving the Earth
SQF, IFS & BRC System Development, Implementation & Certification Consultant

Internal Auditor Training/eConsultant/CB/SQF-GAP/PCQI OnlineTraining

 

www.GlennOsterConsulting.com

 

NEW - GOC BLOG - www.GGGGG.monster

 


#3 QC in NC

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Posted 27 September 2019 - 12:07 AM

Thank you for the clarification!

 

Follow-up question:

Is there a scenario where we could have justified packaging the product after the mistake was noted? Management wants some assurance that our decision was correct; they want to be sure that we didn't overreact and make a choice when there were other options. (options that would have been less costly!)



#4 Charles.C

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Posted 27 September 2019 - 06:11 AM

Thank you for the clarification!

 

Follow-up question:

Is there a scenario where we could have justified packaging the product after the mistake was noted? Management wants some assurance that our decision was correct; they want to be sure that we didn't overreact and make a choice when there were other options. (options that would have been less costly!)

 

One less financially negative possibility - Find a buyer for a (declared) "mixed" product. (I assume this was purely a quality, not a safety-related, blunder).

 

Additionally here is the SQF definition of food fraud -

 

As  defined  by  Michigan  State  University,  a  collective  term  used  to  encompass  the deliberate  and  intentional  substitution,  addition,  tampering,  or  misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product, for economic gain.

 


Kind Regards,

 

Charles.C






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