7 replies to this topic

[Sophia G]

I just started as the QA Manager at a new dehydrated meals manufacturing facility two days ago. Already, dealing with a major issue. The past QA Manager left the company in April 2025, and the facility was without QA Management for 5 months. 

 

The past QA manager often extended shelf life (for Best Before Dates) of various spices, freeze dried vegetables, freeze dried cheeses, powders, and herbs. They primarily used supplier granted extensions, or a combination of in-house Aw testing and third party testing (APC, Coliform, Molds, Yeast) if supported by supplier. In the 5 months since they left, operations extended the shelf life of 25 different spices, dried chilies, dried fruits, and herbs using ONLY organaleptic and in house Aw testing, and used these ingredients with "extended" shelf lives in many different finished products. The majority of Aw measurements came in between .2-.4, with the highest being .58 .

 

I am at a LOSS for what to do here. I've started by placing all expired raw ingredients that weren't properly tested and extended on hold. For finished products that have already been made with these ingredients...??? Do I send in a representative sample of finished product lots for APC, Coliform, Molds, Yeast and hope for the best? Put all finished product that used these ingredients on hold? Lean on Aw, original COA, and storage conditions and scientific evidence to address inherent risks to each product (ie inherent risk of salmonella, original COA showed a negative result, water activity is well below .85 and product has been stored unopened in a dry environment) and chalk it up as a devitation? Prepare myself for a market withdrawl?

 

OH, we also have an AIB audit in two weeks :)

 

Thank you in advance!!

[MDaleDDF]

I'm not in the RTE or RTRH biz, so I won't wade in too deep on some of this.

I will say this:   Shelf life extensions are for rare situations, not business as usual.   I have asked for or done my own SLE's a handful of times in 20 years.   Button that shiz up.  Immediately.   What to do with current product won't matter much if you're dealing with this same issue again in a few weeks.

As far as what to do with product already out there, I'll yield to someone with more experience in this area.   if you DO decide to path test, and it comes back showing anything at all, you're definitely doing a "product withdrawal"...I won't even get into the term itself, lol.

I'll be interested to hear what folks say about your current finished products.   From what you say, it sounds like they were all done with some testing and were issued SLE's on the ingredients they contain?    If they contain EXPIRED ingredients, that's another discussion?

Man, all right before an audit, yikes....

[GMO]

Ok.  You have found this issue and it needs sorting.  The one thing you can't do is cover it up.

 

The most senior leaders need to be made aware that it's a potential crisis situation.  But honestly if any ingredient is "best before" and not "use by" the risk will be low.

 

Some things I'd do before I did testing.

 

Record EVERYTHING.

1. Change onto fresh batches of stock for anything you do not have extensions for.
2. Hold anything on site now but wait on stock which has left your control.
3. Talk to the suppliers and see if they'll extend life even if they're pushing the onus onto you to check organoleptic, Aw etc (which you have).  Ask for urgent responses.  Ask them to explain to you the risk even if they refuse and if they will share their shelf life data with you.
4. Find out which are denied or you don't have information on and so where the risk is.
5. Look at your own in house shelf life assessment and how long / how clean that is.
6. Risk assess the whole lot vs consumer use and if that's likely to have any kind of kill step.  Is it a problem for food safety?  My gut feel is not a lot more than the baseline unless ingredients could have absorbed moisture.  Is it a quality risk?
7. Reconvene your crisis team and make a call, justifying and recording that call.  THEN if you are undecided, do some testing.
8. Once the call is made, dust has settled, make sensible decisions about the ingredients you still have, which need scrapping etc.
9. Then do some RCA on why you're continually extending ingredients.  I suspect MOQs will be part of it but work with procurement so it's not the norm anymore as much as you can.  

AIB can at least then see that you've made a sensible call, you've recorded why and you have some level of CA/PA

[Tony-C]

Hi Sohpia,

 

I now see that you double posted so I've copied here my reply here and arranged for the other one to be deleted.

 

My sympathies, this is a right mess, I’ve known the odd incident with expired ingredients but this is an inherent problem, I mean is anyone managing anything there at all?

 

I would do three things and and document everything you do:

 

Put Finished products on hold and positive release on meeting full specification including micro.

 

Put all expired ingredients on hold and get a summary of ingredient, amount, date of production and date of expiry, supplier extensions granted and tests carried out so far. Decisions will then need to be taken by management as to whether all of this stock can be dumped (which would be an ideal situation) and to get in new stock or whether to organize further assurances, testing and use based on positive release.

 

Conduct a root cause analysis to find out why so many ingredients are expiring before being used, stock control/rotation seems shot or order quantities have been too high. Take out appropriate corrective action.

 

Good luck,

 

Tony

[G M]

As Dale mentioned, extending shelf life is not something I would even consider doing very often.  It is a bit troubling that this has become such a common practice for your team they were doing it dozens of times in a matter of months.

 

I can only guess there is some economic motivation behind not acquiring quantities that can be used before the shelf life is reached.  This seems like a fundamental cultural change that needs to happen to prevent these extensions in the first place.  The problem sounds extensive enough to begin raising questions about fraud if your customers find out what is happening.

[MDaleDDF]

As Dale mentioned, extending shelf life is not something I would even consider doing very often.  It is a bit troubling that this has become such a common practice for your team they were doing it dozens of times in a matter of months.

 

I can only guess there is some economic motivation behind not acquiring quantities that can be used before the shelf life is reached.  This seems like a fundamental cultural change that needs to happen to prevent these extensions in the first place.  The problem sounds extensive enough to begin raising questions about fraud if your customers find out what is happening.

Some places have issues with minimums too.   We have one raw ingredient that lots of places use a little bit of, and the manufacturer stopped taking order for less than a truckload.   So we did some favors, order a truck, distribute it to a few folks, and use the rest in our production.  They get what they want and we make a tiny bit of profit.

But we have a few items that minimums really paint us in a corner as well.   The only thing you can really do (which we do) is price it into the product, and throw out what you don't use before the date is up.   Which is a bummer, I hate throwing stuff away, but hey..... what can ya do?

[TimG]

I've had a request or 2 on extending shelf life for honey from our bulk customers. I would think shelf-life extensions would be risk based and if I were you I would reach out to the supplier first.

That being said, honey lasts forever, and I have had 1 true extension request in over a year of being here (the other was because they mistakenly put 6 months instead of 2 years as the shelf life). It's definitely not something that should be happening as often as you describe.

[MDaleDDF]

I've had a request or 2 on extending shelf life for honey from our bulk customers. I would think shelf-life extensions would be risk based and if I were you I would reach out to the supplier first.

That being said, honey lasts forever, and I have had 1 true extension request in over a year of being here (the other was because they mistakenly put 6 months instead of 2 years as the shelf life). It's definitely not something that should be happening as often as you describe.

Didn't they just find like a jar of honey from Roman Empire or something that was still safe to eat?    Thought I saw that in the news....