We do run a small bakery trying to get the BRC certification, hopefully this summer. We bake bread --> slice it --> and pack to a closed bag.
We do declare the average weight on nearly all of our products and we were doing the manual weight check by sampling 10 breads hour or per run (if run was shorter than 1hr). we then check the average per every 5 breads and do the rolling average for the next checks.
Following the bakers standard and EU weight legislation I have decided the weight checks must be increased to minimum 20 per run or 10 per 15 min (if run is longer). However, my staff is now struggling with manual weight calculations, because there is more to calculate than to pack. We have assessed the weeks worth documentation and we know that there is nearly no product which falls under declared weight. they happen occasionally once or twice within 24hr or not at all. I wonder then if I have to do the average check if all my checked weights are above the declared weight? the only thing i have found was:
14. The Directive sets out three rules with which packers must comply: - the actual contents of the packages should not be less, on average, than the nominal quantity; - the proportion of packages which are short of the stated quantity by a defined amount (the “tolerable negative error” or TNE) should be less than a specified level; and - no package should be short by more than twice the TNE.
We do have T1 and T2 established as well, but we never reach these values.
If i only check the average of 10 products, where one product fell under the declared weight, would i be ok?
It rather depends on what you mean by "OK?"
(Definitive information on this topic requires a copy of the "Packers' Code (1979 !)" which is an elusive object albeit still commercially available (a summary of its contents are in file pk2 below). Other available publications, eg Welmec series contain, afaik, summaries of aspects in the Packers' Code document.).
IMEX of exports to UK/EEC some Companies simply avoid the control complexities discussed below by substantial overfill and accepting the financial hit.
I assume the OP comments relate to this document -
pk1 - UK weight control - Guidance_-_The_Weights_and_Measures__Packaged_Goods__Regulations_2006_v.4_December_2015.pdf 644.22KB
You did not mention if the EC "e" logo is directly involved so I assumed not. This has its own, relatively well-defined, expectations.
I also assumed a checkweigher is not currently involved.(there is considerable discussion on using such option in various files attached below).
I noted/ignored some specific comments in pk1 related to bakers/bread packing.
I assume by "OK" you mean that your system will be accepted by a W&M Inspector as equally effective when compared to the "reference test" as discussed in pk1. (BRC acceptability is presumably a separate issue which I have ignored for present purposes). For example quoting pk1 -
16. The packers and importers checks need to be ‘sufficiently rigorous’ to ensure that the packages are packed to meet the three packers’ rules. This implies that the system should be as efficient as a reference test to control the average quantity and the proportion of packages with a deficiency of more than the TNE.
(Rule 16 appears to be interpreted as, inter alia, requiring compliance with Rules 17 - 19), ie -
17. In the design of the system, attention is recommended to the following issues:
a. for processes controlled by sampling, that the sampling plan is specified and that the target quantity and control limits are appropriately set,
b. for packing lines controlled by checkweighers, that the set points are appropriate,
c. that checking or measuring equipment is properly maintained and checked,
d. that the system should be formalised and reviewed regularly for its appropriateness, and include corrective actions and records that must be made,
e. that the system should specify the training for staff to ensure that the system is adequately implemented
18. Further advice on designing and setting up quantity control systems is contained in Appendices C and D of the Packers’ Code.
19. All products are required to meet the three packers’ rules at the time of packing. For desiccating products, which may lose weight after packing, the onus is on the packer to prove that any subsequent failure was due entirely to the desiccation of the product contained in the packages after they were made up.
A quite nice detailed example (pg 23 et seq) is given in pk1 to illustrate how you can ensure compliance with the reference test. This uses a specific sample size/methodology (ie 50/XYZ). Regardless, afaik, the choice of your control system/sample size is in Principle entirely up to you since the Inspector's reference test is independent of yr implemented setup. However I assume you realize that sample sizes/methodologies other than 50/XYZ require the use of additional "factors" such as noted in pk1 ..
In addition to Post 4, material in pk1 and other files (eg pk4,pk5,pk9) attached below enable a "success" prediction for the effectiveness of various alternative setups when compared to the " reference test" procedure. This involves hypothesis testing which requires some basic statistical capabilities (eg see AnnexD,pk5).
Some related files which I found useful -
pk2 - 2.2.3_Packers Guide_Version 4.01-1.pdf 74.71KB
pk3 - Welmec Guide_6.4_2015_Guide_for_packers_and_importers_of_e-marked_prepacked_products.pdf 934.23KB
pk4 - Average weight,compliance 3 rules for Packers pdf.pdf 863.97KB
pk5 - WELMEC_Guide_6.5,2012,-i_2_Cntrls_By_Competent_Depts_on_e_marked_Prepack.pdf 889.77KB
pk6 - Principles of Checkweighing,Mettler.pdf 589.83KB
pk7 - weights and measures (UK) 2006, No.659.pdf 239.04KB
pk8 - Average Quantity System,Queensland,2006.pdf 929.46KB
pk9 -NWML, quantity-average-guidance-2007.pdf 354.68KB
pk10 - UK,2006,No.659 weights and measures (packaged goods) Regs.pdf 148.45KB
pk11 - EEC Directive 76-211(,1976) weight prepackaged products.pdf 736.67KB
pk12 - Welmec Guide,6.6,2013,recognition of procedures.pdf 538.76KB
PS - I suspect that control characteristics of US Systems may not relate to this thread unless they incorporate T1/T2 concepts.
PPS - JFI these.3 previous (UK ) threads are vaguely related to this thread -
Predictably, all the above had difficulties with the complexities of the UK Weight control scenario.