9 replies to this topic

[cookinmaple]

I am looking for some input on a minor we received that I think I could appeal.

 

"Under 2.4.5.1, Minor NC. The hold and release-non-conforming product program was documented, however "hold labels" were not observed in place for the materials in the warehouse designated as "on hold" according to procedure. Several defective materials were segregated and observed in the warehouse."

 

What the auditor is speaking of, is finished product labels that aren't compatible with hot products because of lifting, but still suitable for use on cold product. We intent to use these label when we label product after its been cooled. I had this pallet put aside so I could take inventory of it but did not have time to complete before our audit, and that I take ownership of. 

 

What I am questioning and need help with is, what would this be classified as? Should these labels be on HOLD and then released each and every time we do use them? 

 

Thanks for your input!

[Setanta]

I may not have understood this correctly...but if anything is on Hold, whether it is packaging, ingredients, finished goods, or even equipment, it must have a tag on it identifying it as a Hold item.

 

If your solution to labels that have restricted uses is to put them on Hold, and release them as needed, they will need to be marked as on Hold, also.

Edited by Setanta, 24 January 2025 - 02:27 PM.

[cookinmaple]

I may not have understood this correctly...but if anything is on Hold, whether it is packaging, ingredients, finished goods, or even equipment, it must have a tag on it identifying it as a Hold item.

 

If your solution to labels that have restricted uses is to put them on Hold, and release them as needed, they will need to be marked as on Hold, also.

 

Its something we don't want to place on HOLD because we will be using them on cold product, not hot. Releasing the labels multiple times don't make sense to us as they are good and don't believe they should be held to start with. But my logic might be wrong. 

 

To clarify my question, should low rotation packaging be on HOLD? 

[SQFconsultant]

I see no grounds for requesting an appeal and all you need to do is place a wrap around tape on this hold material, write the the tem hold information on it and make a record of it abd follow up for release removal of tape. Which is what we do. 

[Kryssie]

Its something we don't want to place on HOLD because we will be using them on cold product, not hot. Releasing the labels multiple times don't make sense to us as they are good and don't believe they should be held to start with. But my logic might be wrong. 

 

To clarify my question, should low rotation packaging be on HOL

In reviewing your statement, it appears that the products are on Hold, but due to lifting issue with the stickers you have chosen not to label.

 

Remember the status of every product in the process flow must be defined and if these products are being held for whatever reason they must be tagged based on the requirement of the standard. 

The auditor is auditing the plant against what you have documented also, so you may want to review your procedure as to how you manage this step in your process, not only to show hold but to prevent inadvertent use of the product.

[Kryssie]

It is a minor and you may consider reviewing your Hold procedure to include what is specify done at this process step to manage the hold seeing that the use of labels is senseless. 

 

The auditor is auditing against your documented procedure and if you say items on hold are manage through tagging with a Hold sticker that is what  the auditor expects to see.

 

If you have a unique situation, you should call that out in the procedure and state how that process is managed to prevent inadvertent use of the product. How do you manage that process step seeing that you can't sticker the products.

 

You could also reach out to supplier who can provide you stickers with adhesive that can hold or as suggested above shrink wrap and place label inside the wrapper.

[kingstudruler1]

Why did the auditor THINK it was on hold?   Only becuase it was set aside or is there a nonconformity entry somewhere,etc? 

 

Are the labels two different items / item numbers, or are they the same item / item number?   Does your bill of material indicate which one to use on which products, etc?

 

If there is not method for determining a hot compatable vs a cold compatable label and or where they are used, I can see his/her point.   They could be used interchangibly.   Which could lead to non conforming product.   If there is a method for determing a hot vs cold compatable label and which products they are used on, im not sure I get where he/she is coming from.   

 

If there is no way to know the difference between a hot vs cold label, they probably should be on hold, segregated, and released as needed by a resonsible person.   

If there is a way to determine a hot vs cold label and where they are used, you need to do a better job expaining the difference to auditors.  

[TimG]

Hey Cookin, correct me if I am not understanding. 

You have product on hold and your procedure says they need to be labeled 'hold,' but the hold stickers won't stick to hot product so you were waiting for it to cool?

 

The code he referenced was 2.4.5.1 and I believe he is specifically looking at    i.  Non-conforming product is quarantined, identified, handled,...

 

If it was on hold and not properly quarantined or identified, OR if your program says you label them, but you hadn't labeled them (say what you do, do what you say), then I believe the minor was appropriate.

[Scampi]

start at the beginning------------why did the auditor know they were on HOLD

 

If you had product tagged HOLD and it was NOT were your HOLD section is, then you are in deviation plain and simple

 

If you want to use those labels on different product, then you need to train and take them off HOLD as there is nothing WRONG with the labels themselves

[jfrey123]

It's a little hard to follow you OP, but lemme know if this is what you meant: 

• You had released labels to be placed on finished cases, but the cases were hot and would cause the labels to lift so you were waiting for them to cool. 
• Auditor observed the released labels were placed somewhere to wait for the cases to cool, but the labels staged somewhere special while you waited.
• Auditor interpreted these labels as being "on hold", or that the product was "on hold" pending the cooling? (this is where I'm unclear)

If you're waiting to apply finish labels, you could consider a temporary pallet label identifying the product while you wait (something as simple as taping a printed 8.5x11 paper onto the cases would be sufficient).  In my mind this would still be considered WIP and you could reflect this in your flow charts as such.  Don't release the finish labels from your secure area until the product is ready to be labeled, just as a good label control program (to ensure an employee doesn't put finish labels on the wrong product).