Internal Testing and Using Results on a CoA

Good day all,

I have a question about testing for certain product parameters internally. I am working in a start-up plant-based dairy facility. As of now we are on final formulation steps for our product SKUs and are completing a lot of product characteristic and quality tests via third party. This is both expensive, and time consuming. My management is preparing to invest in the beginning of what will be an internal quality lab. They do have some questions that I have opinions on, but would love some communal insight, if possible.

My question here is, if we are to test for certain product characteristics, such as, but not limited to, Brix, Viscosity, Particle Size, are we able to include this information on a CoA to provide to a client or are there conflicts of interests that limit this? Any form of microbiological analysis will be done-so third party moving forward.

I have performed internal testing before and included the data on company produced CoAs, but am unsure as to whether or not this was an internal agreement, or if there are no concerns in doing this in general. 

Thank-you for any and all advice.

Gareth

Hi Gareth. From my experience making plant-based products for Loblaw, it's completely fine to perform some tests in-house: we're testing for Fat%, TS and Moisture (by CEM tracking machine), viscosity, pH, and pantone color. All test results have always been accepted by Loblaw (as well as by other customers) - though, micro testing must definitely be done by the accredited lab, either internal or external. No agreement AFAIK on internal testing. However, let's wait on other comments.

Are you asking if "in house" testing data can be put on a COA?    The answer is yes.  

I would NOT voluntarily add any information regarding characteristics or properties that would be considered proprietary on a COA unless or until it's a deal breaker for a customer you covet

pH, colour, brix are all safe bets to include, my I would keep everything else to myself on this one, particularly since the competition in this space is so competitive

FYI I know someone with some absolutely amazing plant based recipes that could probably be purchased to the right customer (not fluid products) that are at least head and shoulders above anything currently commercially available that would be ready for batch up

Hi GarethToon,

It's very common for production facilities to have their own internal QA labs. The labs generate results that are indeed used on CoAs for outgoing product. Many facilities even have internal microbiology labs. The key is to develop a lab program that is trustworthy from the perspective of your customers. If I was your customer and saw that you made the switch to internal testing, I would want to know:

- How are your technician trained, and how is this documented?

- Does your lab have documented SOPs for all methods?

- What methods does your lab use in its analysis? (are they AOAC recognized, from the USP, etc?)

- Is the lab equipment you use suitable for its purpose?

- Is your lab equipment properly maintained and calibrated?

- Do your technicians participate in any kind of proficiency testing?

- Do QA staff review lab results, and are QA staff independent from production?

- Does the QA department have the ability to hold product based on lab results?

These are some of the questions that come to mind. Naturally, you may not be asked these right away by a customer because internal QA labs are very common. But if you follow any kind of 3rd party auditing scheme for your plant, the lab will be audited on these items and more.

^Scampi makes a good point about proprietary information, my post doesn't touch on that issue at all. Of course you can and should test for all parameters that are important to your product, and the testing should have integrity, but not all values need to be reported externally on a CoA. You can use these results to track your quality internally.

Wow, thank-you everyone for your timely input! These all align, for the most part with what I was originally thinking. Having the reassurance is of benefit to me. Main conclusion that I was looking for, in broad strokes at least, is that it is permissible to perform internal testing and use it on CoAs - within reason. 

A secondary question from me. Does any form of lab equipment need to be isolated from the production area? We are dealing with some restricted floor plans and were hoping to potentially place the lab equipment in an area adjacent to a currently unused packaging area. I understand that most lab equipment should have it's own designated 4-walled area, but alas, we have run out of room. Does the placement of this lab equipment take away from its legitimacy or is it acceptable if the environment does not interfere with the operation of the lab equipment? Solid, immobile countertops would be installed. 

Scampi, thank-you for the comment, and I appreciate the thought of providing recipes, but we are dealing with fluid products and have a technologically unique production plan and formulation in the works! :).

Not sure about production area - however, we're doing some test (e.g. viscosity, brix, pH) in the lunchroom as we also have lack of space. So far, no objections from the customers.

I would think placing a lab area near a production line would be ok as long as the type of testing you're doing is not compromised or contaminated by production, and vice versa. For example, you would never have a microbiology lab that was not in an enclosed room. You also need to consider if the testing is a risk to the product. Are you going to be using any reagents in the lab that pose a risk to contaminating your product? Are any of the lab chemicals dangerous to keep on the production floor? Would the lab be using any equipment (glass, cloth towels, tape) that would otherwise not be allowed on the production floor? These are good questions to ask yourself.