SQF 12.8.1.4 - Controlled Disposal of trademarked materials
Hello everyone! So I recently experienced my first audit as a new SQF Practitioner. We are a small Storage and Distribution operation in Ottawa Canada for Fresh Produce and some packaged Meat, Dairy and frozen goods. These are all pre-packaged items that leave our warehouse in the same state.
I am reaching out today for some guidance on one of the Non Conformance's. All product we handle comes in cases and goes out the same. We do breakdown some cases of fruits and vegetables to be sold in smaller quantities for those who cannot use a case of product.
The cases from those products with Trademark names on them are broken down and put into the garbage and it is picked up daily. We have a Waste Disposal program in place. However, it does not specifically make any reference to how we dispose or handle the disposal of trademark materials.
12.8.1.4 of the code states: Where applicable, a documented procedure shall be in place for the controlled disposal of trademarked materials. Where a contracted disposal service is used, the disposal process shall be reviewed regularly to confirm compliance.
So this was a non-conformance when in the past several years of audits it has not. I understand this goes to the prevention of food fraud. Is this as simple as adding a line item to my existing program that specifically says how we destroy those trademark boxes?
How does one determine if this is applicable to our operation?
Appreciate any guidance/experience you can share.
Thank you in advance.
Cheers, Kevin
As you've stated that your waste is picked up daily (by WM or similar) I would just include a line in your waste management procedure that trademarked items are broken down and picked up daily by ACME waste and taken directly to a facility for recycling that renders them un-useable that should be sufficient
I would maybe include some language that the boxes are rendered unusable by the breaking down process (as the boxes cannot realistically be reassembled)
Given that your not destroying rolls of packaging (as an example) this should be sufficient to close the non conformance
I would add however that you will need to establish how you render destruction steos on your end before it goes to recycling.
We deface all trademarks, labels etc prior to them going into recycling and then have a letter on file that indicates what the disposal ckmpany actually does to ensure complete destruction.
Hi Kevin,
:welcome:
Welcome to the IFSQN forums.
Your procedure and contract should stipulate that your waste is destroyed.
You should manage your end by defacing the materials so that it is impossible to resell.
You should log the trademarked material and quantity that is being disposed of on a daily basis.
Kind regards,
Tony
We had a log of the trademarked items and kept them in a secure location. Each month a shredding company would come (to collect other materials) and if we had any trademarked items to dispose of, we would personally put it in their bin and get them to sign that they had received it. Our items were only small tags so did not take up much room. We had a heading in our procedure that noted this.
In addition to the above, we also have all of our recyclers give us a Letter (or certificate) Of Destruction for the upcoming year that states: