I am fairly new to my job role and with even more changes in that i have been presented with a new problem.
as im sure you are all aware there is new regs coming in to effect from December to which i have now been give responsibility of ensuring our compliance ^^ not as easy as you think it might be because where as most company have had some 2 or 3 years to prepare, an npd department containing packaging and labeling specialists, my small company i work for felt leaving it until now to address the issue!!
Anyway i have some questions id like to ask and rather than spend my non working hours doing that as i have no spare time at work currently to address this with the time i need to i thought best to get on this forum to get some much needed advice.
Please note our products do not go to main stream supermarkets like tesco or marks and spark its generally aimed at restaurants and the like.
Questions 1) as a quality auditor in production i was always lead to believe that it was against the law to: place labels on labels or where a printed label is part of the film, place a different label over that for example:
We have a fresh goods product that has a printed film with picture nutritional info and bar code and what they have been doing is for another customer is place a sticky labeled with different bar code over the top of that.
now i think this is illegal and if im right i need to call a meeting and shove some document or something in their faces to make them listen perhaps reference to a particular requirement or regulation clause would be great if at all possible.
Question 2) Our fresh product is made with a USB date of about P+10 days the product can be frozen for 6 months, defrosted and then used within 3 days of defrost. The production Film contains printed USB date and information about defrost however over the USB date Print where a date would be printed on they place a BBD sticker of +10 regardless if it is sent out as fresh or frozen (some customers ask we freeze it before delivery)
So...am i right in thinking if the film says USB this is what we should use based on the product spec, in this case its ok to use a sticker for fresh or frozen in the space provided on film provided it says USB not BBD? and that if a customer asks us to freeze it for them on day of production then the effective USB date would be 6 months + 3 days and not from production +10 days + 6 months + 3 days. ( the issue being a difference of freezing on day 1 to freezing on day 10.......
Question 3) As we no longer have an NPD department and im reduced to performing 5 different job roles now are there any accredited/ certified businesses that for example specialist in taking information from us, either in form of a printed film or information about product. That this business can proof read / vet our products packaging/ labeling meets legal requirements? U heard SGS do this service or something similar but would not be able to perform it for us due to fact they certify us against BRC.
Again this is extremely important its out of my area of expertise and i need to resolve it asap due to fact there isn't the skills, experience, or resources in place currently to address it..
(before you all say BRC section 1 -- i have been shouting it and food safety law (HACCP) for 3 months and have even threatened to resign over the managements decisions on the plus we got a new MD and hes on the ball so i expect some changes for the better soon)
Thank you for any help in advance with the above i appreciate it...