Questions about what should be considered rework

Hello, 

We are an herb and spice company and there is some internal debate right now about what we should classify as rework. I know the SQF definition of rework is "Food, materials, and ingredients, including work-in-progress that has left the normal product flow and requires action to be taken on it before it is acceptable for release and is suitable for reuse within the process". 

Now we have a few different scenarios that we have been treating as rework, but not sure if we should or just consider it regular production. 

First example: Organic raw material was received and packaged as tea. Later an issue was discovered with the organic paperwork, and not the material (while completely food safe) cannot be sold as organic, it must be sold as conventional product. The affected material was removed from stock and pulled off the shelves when the issue was discovered (no recall necessary as per our organic certifier, we just could not sell remaining stock as organic). 

We have a conventional item for this same tea, so we want to remove the sealed bag of tea bags from the old tea box and put it into a new box that is not labelled as organic, so we can sell it as conventional tea. I consider this rework, as we are taking a finished good and reworking it into another different finished good. (everything will be traced in our system so no traceability issues). Is this actually a rework?

Second example: Some items were originally packaged as 1 lb bags, but due to price are found to sell better as a 1/2 lb bag. We want to remove the 1 lb bags from stock (already finished goods) and bring back into the packaging room and repack into 1/2 lb bags. Again everything traced, material will have new lot number and item code, and old lot number and item code will be traceable on the workorder and in our system. I would also consider this to be rework. 

In these two examples, our regular procedures will be followed, the only difference being that raw materials will not be used, we are using finished goods and making it into a different item. If we are considering it rework, we have a different category of workorder,, so we can track rework items and provide to an auditor if asked. I consider than in these examples the material has "left the normal product flow" since we don't normally package from finished goods, and so therefore consider these examples and similar ones as rework, but am I mistaken here?

Any advice would be greatly appreciated!

Wouldn't this be defined as repackaging?  You aren't really "reworking" it because you aren't making any changes except to the packaging.

We would consider your first example a rebrand and the second one a repack. For us, rework would be taking finished product, reclassifying it as raw material, and incorporating it into the formulation of a new lot of finished material.

I agree with @Lynx42 here, this is repacking. Rework is taking a product or material with a certain formula and working this into additional like products or materials.  If you repackage into different weights, sizes, or just general labeling (organic) you are not taking a like material and working this into an additional functional material your just repackaging.  

It would all fall under the rework - recoup, rebranding, repackaging - to me and our operations all of this would be rework and then we'd note exactly what the sub-classification was - repack, rebrand, etc.

From SQF glossary:

Rework: Food, materials, and ingredients, including work-in-progress that has left the normal product flow and requires action to be taken on it before it is acceptable for release and is suitable for reuse within the process.

I'm iffy on your first scenario.  Seems like it could qualify for rework as it is departing your normal organic flow and reentering into your inorganic flow.  Also seems like lot coding wouldn't change, and there's no prohibition against taking once organic material and selling it as non-organic.  If your non-organic flow is the same as the organic minus the receiving paperwork for raw materials, then you can make a case it was packaged under your non-organic flow and was only a relabel.

Second scenario is rework in my mind, 100%.  It's being repackaged with new lot coding and date information, and new packaging also needs to be traced.  For the new lot you're creating, the input lot can and probably should be shown as your input material.  And unless your packaging is a perfect process with zero loss, you're going to need to account for the loss during the reprocessing step.

I would also call both of them rework.  You're taking either finished goods or intermediate stage materials and returning them to an earlier step in the flow chart where they become part of a new lot or batch.

Hi VictoriaRK,

I would call both rework as it clearer that the repacking needs to be managed to ensure that you are maintaining your traceability, ensuring compliance with specification and taking into consideration and adjustment there may need to be to the best before date based on how old the product is when it is repackaged.

Kind regards,

Tony

Rework: Food, materials, and ingredients, including work-in-progress that has left the normal product flow and requires action to be taken on it before it is acceptable for release and is suitable for reuse within the process.

The other issue here is "left the normal product flow".  Repacking is normal product flow for us, also, using extra finished product from one product (bulk) in another blend is also normal product flow with limits and specifications.  The product is acceptable for release or production and the Release documentation for clearly states that.

Many of our products are either sold as manufactured or used as ingredients in the next product, or the next....  All are completely traceable including packaging.  We do not consider that rework.

Rework - Just on the fact alone that they are being assigned new lot numbers. 

To me you are following all the right steps and will have complete traceability.  So who cares what you call it as long as you are following protocol and the finished product complies with the applicable country laws.  As you see above everyone seems to have different opinions on the definition of the word 'rework' and in my opinion it is not clearly defined in any of the GFSI schemes.  If you are unsure just always do what you are already doing, you have the records, you have the proof, thus there is no non-conformance in my mind that can put you at fault just because the term rework is vague.