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Need help with minor nonconformance on Checkweigher T2


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#1 nidiagonzc

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Posted 21 July 2020 - 10:49 AM

Hi all

BRC audit gave us a Non conformity due to our QA sample for underweight T2 was under this value (-0.1g). It was rejected. But the auditor said that our QA should be made at exact T2.

Let see for example the target weight was 250g TNE 9.5 and T2 will be 231g. So according to the auditor our sample should be made 231g not less as according to the law 231g have to be rejected always. In our checkweigher the exact T2 is not rejecting.

We recently have another calibration and everything is ok. I did explain this to the auditor but still gave us a minor for it.

Any advice?

Anyone have experience



#2 olenazh

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Posted 21 July 2020 - 12:27 PM

Not sure, what T2 (target 2?) is - but do you have a range for your product weights? Is it possible to pack at exactly target weight?



#3 pHruit

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Posted 21 July 2020 - 12:35 PM

Schedule 3 of the Weights & Measures (Packaged Goods) Regs suggests a TNE of 9g for packs between 200-300g, which would give a T2 of 18g?
In any case, in a strict sense I don't believe that a product being "at" the T2 limit is a problem itself, given the wording of part 4(1)© of the Regs: no package shall have a negative error great than twice the tolerable negative error.

My emphasis on the "greater than" element, as this confirms that a package with a weight at exactly the T2 limit would still comply.

 

Nonetheless I suspect that part of the auditors point is that there is still a tolerance in the calibration, and perhaps this should be taken into account to ensure compliance?
If your scale is accurate to +/-0.1g, then allowing a product through that was weighed at exactly T2 could theoretically release product that is actually T2-0.1g, which would be underweight and not meet the third of the "three packers' rules" required in the regs?



#4 Charles.C

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Posted 21 July 2020 - 03:29 PM

Schedule 3 of the Weights & Measures (Packaged Goods) Regs suggests a TNE of 9g for packs between 200-300g, which would give a T2 of 18g?
In any case, in a strict sense I don't believe that a product being "at" the T2 limit is a problem itself, given the wording of part 4(1)© of the Regs: no package shall have a negative error great than twice the tolerable negative error.

My emphasis on the "greater than" element, as this confirms that a package with a weight at exactly the T2 limit would still comply.

 

Nonetheless I suspect that part of the auditors point is that there is still a tolerance in the calibration, and perhaps this should be taken into account to ensure compliance?
If your scale is accurate to +/-0.1g, then allowing a product through that was weighed at exactly T2 could theoretically release product that is actually T2-0.1g, which would be underweight and not meet the third of the "three packers' rules" required in the regs?

Hi pHruit,

 

IIRC a similar logic occurs when designating critical limits for temperature CCPs in cooking processes (The precise to-be-applied correction can become quite "involved" if one includes statistical coverage factors).

 

 I would anticipate that the precise interpretation/application of T1, T2 must surely be stated somewhere in the numerous examples which I recall are available in the associated Guidelines, eg -

 

https://www.ifsqn.co...ol/#entry162192

 

(I agree with yr logic but offhand I don't recall any mention of a calibration correction however  there are specific Guideline segments  on "checkweighers")


Kind Regards,

 

Charles.C


#5 pHruit

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Posted 21 July 2020 - 03:48 PM

Hi pHruit,

 

IIRC a similar logic occurs when designating critical limits for temperature CCPs in cooking processes (The precise to-be-applied correction can become quite "involved" if one includes statistical coverage factors).

 

Indeed - I was thinking of the setup of my own divert temp probes as I was typing it ;)

Such adjustments are fairly standard for critical temperature monitoring applications, but like you I'm aware of far less discussion/considerations of this in the context considered here. Our local trading standards departments used to do "proper" inspections with their own check weights and have always been happy with an "exact" T2, as long as the accuracy of the scales was within a certain range (with tolerance dependent on the target weight range). I've seen far less detailed consideration of the nature discussed in this thread, so I genuinely think that it is possible the auditor may have taken a more pedantic position than a regulator would - alas that doesn't mean they aren't potentially "right" in terms of the actual metrology which can make it difficult to argue with, other than to provide some sort of corrective action that addresses the (theoretical/potential) problem.



#6 nidiagonzc

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Posted 21 July 2020 - 08:04 PM

First of all, thanks for your prompt response.

Today, I have talked to the auditor today again as I feel is unfair they way he make his comment. I have checked with the external company that is in charge of the calibration and they said T2 still complies with the regulation. to see the effective rejection I should go for doing a samples test weight less than T2.

I explained this to the auditor that suggests that the checkweigher should be validated??



#7 Charles.C

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Posted 22 July 2020 - 12:34 AM

First of all, thanks for your prompt response.

Today, I have talked to the auditor today again as I feel is unfair they way he make his comment. I have checked with the external company that is in charge of the calibration and they said T2 still complies with the regulation. to see the effective rejection I should go for doing a samples test weight less than T2.

I explained this to the auditor that suggests that the checkweigher should be validated??

Hi nidiagonzc,

 

I thought the NC was based on the quoted auditor's comment/interpretation in OP ?. From a quick look at previously linked files, auditor was incorrect, eg - 

 

A checkweigher shall present the average quantity of product and the number/percentage below TU1 and TU2 of at least every production hour. The packers procedures will include requirements to consider this information and act on it if necessary. It will be very difficult to monitor each hour’s production from an accumulated average (over a period longer than one hour)

 

.

However, checkweighers also appear to have their own specific requirements, eg -

Attached File  checkweigher.PNG   63.28KB   0 downloads

(see file pk5)


Kind Regards,

 

Charles.C


#8 nidiagonzc

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Posted 22 July 2020 - 04:18 AM

Hi Charles

Yes, you are right. When we prepared the T2 samples weights, they should be less than the T2 otherwise the checkweigher will not reject it. However, the auditor says that we should able to do validation of the checkweighers and this will prove that we are packing legally.



#9 nidiagonzc

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Posted 22 July 2020 - 12:07 PM

Hi Charles

Yes, you are right he was wrong. When we prepared the T2 samples weights, they should be less than the T2 otherwise the checkweigher will not reject it. However, the auditor says that we should able to do validation of the checkweighers and this will prove that we are packing legally.



#10 Charles.C

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Posted 23 July 2020 - 07:16 AM

Hi Charles

Yes, you are right he was wrong. When we prepared the T2 samples weights, they should be less than the T2 otherwise the checkweigher will not reject it. However, the auditor says that we should able to do validation of the checkweighers and this will prove that we are packing legally.

Is the validation not available from  the external calibration company mentioned in Post 6 ? Should be IMO.


Kind Regards,

 

Charles.C


#11 nidiagonzc

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Posted 26 July 2020 - 10:26 AM

Is the validation not available from  the external calibration company mentioned in Post 6 ? Should be IMO.

 Hi Charles

 

The auditor want to see how we control this internally.  We do calibration of checkweighers every six months. Is really annoying that this external calibration is not enough for BRC auditor.
Therefore, I need to do this validation and hopefully obtain data to document it.


#12 Charles.C

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Posted 26 July 2020 - 11:18 AM

 

 Hi Charles

 

The auditor want to see how we control this internally.  We do calibration of checkweighers every six months. Is really annoying that this external calibration is not enough for BRC auditor.
Therefore, I need to do this validation and hopefully obtain data to document it.

 

I think I would at this point consider officially questioning the reason for yr auditor's strange demands. Particularly as he/she appears to have an incorrect knowledge of the legal implementation ot T1/T2 factors.

 

as I understand, the validation requirements are summarised on pg 22 of file pk1 in link of post4. i wish you luck because you may well need it.


Kind Regards,

 

Charles.C





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