2 replies to this topic

[Tyler.W]

Hello all, 

 

We recently had an audit for a perspective new customer. One of the things the auditor noted was the need for a Master Label Control Log. We currently have a label approval log which supports the necessary checkoffs for the USDA and FDA labels (i.e Product description/name, net weights, distribution statement, etc.)  but no control log for the approved labels. Any examples or tips on what this should look like? 

 

The auditor also noted a dedicated procedure for label changeovers and a checklist for the changeover. I'm guessing this will mostly just need a clause added to our labeling procedure to include verification of the disposal of any left over labels but I want to ensure I address all the areas I need to so any help with this is also appreciated! 

 

Just an FYI we are a BRC certified facility and currently do bulk batch made labels for whatever we run.   

[Tony-C]

Hi Tyler,

 

That log is a register of approved labels. Approved samples should be available to relevant staff that are checking the labels. Printed packaging should be checked by relevant staff at the goods receipt stage if purchased, or when printed if printing on site.

 

Labels need to be controlled such that only one set of product labels are available at the production line during production. When changing product/labels the production line needs to cleared and product/labels reconciled, all of which needs to be recorded.

 

Your system will require a formal mass balance at the end of each production run, you should know the typical waste during a production run when reconciling the total.

You will also need to take into account any extra known loss/waste of packaging during the run. You need to record the number of labels received, used, wasted/disposed of and amount returned to stores (if applicable). Discrepancies in usage from the norm should be investigated.

 

Relevant info from BRCGS Global Standard for Food Safety Issue 9 Section 6.2 Labelling and pack control is quoted below.

 

Clause 6.2.1 states:

‘There shall be a formal process for the allocation of packaging materials to packing lines and control in the packing area which ensures that only the packaging for immediate use is available to the packing machines.

Processes shall be in place to check label use is reconciled with expected use and the cause of any inconsistencies investigated.’

Clause 6.2.2 states:

‘Documented checks shall be carried out at product changes to ensure that all products and printed packaging and labels from the previous production have been removed from the line before changing to the next production.’

 

There are requirements for offline coding/printing which I have omitted (refer to 6.2.1 in the standard).

 

It is also good practice to retain label samples from the production run.

 

Kind regards,

 

Tony

[GMO]

Tony's covered off the line clearance process.

 

On the log, I'd include key information to that label.  You could also use it longer term for scanning systems so it's a good thing to start to build.  The kind of thing I'd include is what defines that label, some example headers you could have on a spreadsheet could include:

 

Brand

Name of product

Weight

Approved artwork number and version number (it would be great to hyperlink this to the approved PDF if you can)

1D barcode number

2D barcode if you have it, which I'd recommend you do

Any print "flashes" (e.g. "only £1!" or "New recipe", i.e. the kinds of things which can change from version to version)

 

It would be great to also have the specification number as well.  All of the above could be super helpful if you ever face into a recall situation or have a middle of the night "is this the right label?" moment.