Best Practices for Disposing of Old Retention Samples
Hi all, I'm not sure if I've categorized this correctly, but this is on a hot topic that's going around recently at our company.
We need to make space in our warehouse by destroying old samples, including samples of finished goods, and the ones we want to destroy are all past their 'best by' date.
The question is about how we destroy them, and our practice has been to empty each finished good bottle and dump out the contents in the trash, even if they are past their 'best by' date. I'm sure this is not required by regulations, but to be safe against food fraud, this is what we've done. As you can imagine, this takes a lot of extra effort and labor hours to open up bottles to dump them out. What would your recommendation be for this--do the contents need to be dumped out, or can the full, sealed bottles be merely tossed in the trash?
We are following 21 CFR Part 111 in the United States for manufacturing dietary supplements, and we have NSF GMP and SQF certifications.
Matthew
I would recommend documenting that you have destroyed them like you do out dated packaging material.
You can pour them down the drain, provided it doesn't annoy the municipality you send your water to be treated. We have a balance with our city water and have to be careful what we send down the drain. pH Balances, solids, smelly items, it all can affect city water. There is a story about a previous company in this location, they dumped some expired garlic oil down the drain and the whole town smelled garlicky for 2 days! Ooops!
But you should make sure that the product cannot be re-purposed or used by someone dumpster-diving.
I'd get a secure disposal company to take the samples away, destroy them and have certificated records of disposal.
We get to dump ours back and rework it :rock:.
As a previous storm water/ waste water compliance person in a food facility, please make sure if you dump it to the drain, you are getting feedback from your wastewater compliance person. It could cause heavy fines depending on state regulations.
0% chance I'd allow sealed bottles of product to be discarded. Random person finds it at the dump or breaks into your dumpster and sees it, consumes or resells it, your company would be liable for any illness.
I was always taught that food should be denatured in some way when discarding it. Pouring a liquid out of its container seems the easiest. I've seen some fresher food places mix their retains in inedible liquids prior to disposing, it really kind of varies. And while my Google-fu is failing to find a relevant FDA code regarding the topic, I know most of our GFSI codes would mention some type of controlled disposal process (see SQF 11.8.1.6). Now, SQF seems more concerned with controlling the trademark information from a fraud standpoint, but you also wouldn't want someone to be able to take your product and relabel/rebottle it and sell it as their own.
We open the packages and then dispose of them in the garbage.. package contents in one garbage bin and empty packaging in the second. We also fill out a disposal form that includes the lot code, quantity and reason for disposal of the affected product. We keep a hard copy of the disposal form and also enter the information in our disposal log.
These are mostly capsules and not liquids. Thanks for the guidance!
If you don't have one, there is equipment out there which will churn up waste and pick out packaging from it (AD plants use them). If you have a lot of waste of this nature and in more general it could be a way of destroying it on site so that it's not at risk of resale once it's left you. Jfrey's point is valid that there have been cases of waste companies reselling but in the UK at least if you've done your part in terms of certs of destruction etc it's not your liability (don't ask me how I know but I do know) so there is validity to destroying on site if you can.
Ideally (for the planet) if it can go for animal feed or AD plant rather than incineration or landfill it's better. If you really can't destroy on site and it's critical you need to know it was genuinely destroyed, I have got someone to go with the truck before and watch the process. For out of date stock I'm not sure I would though.