How to define a batch for weight checks?
Hello everyone,
I hope you are doing well amidst this lockdown. :spoton:
I would like some help with defining a batch for our products. We have a wide variety of products, meaning that the quantity will also vary,
For example we can make 33,000 jars of olives for an order within 6 hours, that we choose to split in 3 LOTS of 11,000 (A, B, C) for the sake of clarity (not so much for tracability as the raw materials are not individually tracked for each LOT). This is where I have an issue interpreting 76/211/EEC. What would be the batch number, 33,000 or 11,000 or a different number? And subsequently how many weight checks should I perform (80 samples for >3201 units)?
I hope my query was clear enough.
Thank you for your time.
Myrto
76/211/EEC is a Directive rather than a Regulation, so there will be a local implementation of this applicable. I'm not sure what that would be in Greece I'm afraid!
Nonetheless, assuming that all of your products fit the definition of a "prepackage" in accordance with Article 1(2), I'd interpret the definition in Annex II of the current consolidated version (https://eur-lex.euro...6L0211-20190726) as implying that the total "batch" is potentially going to be variable depending on how your products fit into the considerations in part 2 of Annex II.
The sampling count indicated in 2.2.1 of Annex II is partly dependent on what is found by the first part of the sampling (the 80 samples for >=3201 packages you mentioned) - this could be sufficient, but it could also lead to a batch failing, or it could lead to a requirement for further sampling.
I don't know which regulatory body looks after this area locally for you, but it might be worth checking with them for local guidance - certainly here in the UK the Trading Standards services publishes interpretation and guidance on these types of Weights & Measures considerations, and it's particularly relevant given that there is scope for additional interpretation/requirements from individual member states.
Hi,
we are a bakery. We define a "batch" or "Lot" depending on the production size and per line/product/article number
- 24h production of a single product -> 1 batch number per day (dependent on the plant and the shift model we change to the next date at 23h or 6h; but always the same manner per plant for many years)
- several articles per line per day -> same lot number for each product (differentiation by lot# and article#)
Why not to have one lot# per week if the article is produced 24/7? -> traceability (raw material and packaging lots will change over time; we try to minimize change over-> never more than 2 per mat#) and risk reduction if a recall would happen.
Rgds
moskito
Hi,
we are a bakery. We define a "batch" or "Lot" depending on the production size and per line/product/article number
- 24h production of a single product -> 1 batch number per day (dependent on the plant and the shift model we change to the next date at 23h or 6h; but always the same manner per plant for many years)
- several articles per line per day -> same lot number for each product (differentiation by lot# and article#)
Why not to have one lot# per week if the article is produced 24/7? -> traceability (raw material and packaging lots will change over time; we try to minimize change over-> never more than 2 per mat#) and risk reduction if a recall would happen.
Rgds
moskito
There are regulations that state that one batch / 24 hour period is the minimum coding requirement. Thus, you can not have one batch per 7 days.
Dear rmssan
you are right - legal requirements first. But IMO in many countries such regulation does nor exist.
Rgds
moskito
If no such regulation exists, then provided that the exact same input and condition will be used throughout the week, then there shouldn't be any issue food safety-wise as traceability will be intact.
The tradeoff is should there be a problem that warrants a recall, then an entire week's production will have to be recalled
In reality however, maintaining the same condition throughout the week is nigh impossible. Minimum cleaning requirements and hazards analysis of process will reveal that equipment in contact with high risk food items such as eggs, dairy must be cleaned frequently - unless changeovers, maintenance, or cleaning for the next week will not be done.
PS Some would also argue that changing of staff is tantamount to a significant change in the processing condition, especially if the operation involves some manual handling or operation