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2.6.1 Product Identification

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KateG

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Posted 25 October 2016 - 04:57 PM

We are a storage and distribution facility upgrading our system to SQF  Level 2 Food Sector 25 & 26 and are struggling with 2.6.1 Product Identification. 

 

We distribute fresh fruits and vegetables. We've looked up CFR Title 21 Food and Drugs Part 101 Food Labeling and are not convinced this applies to us. 

 

Does anyone out there fall into this same sector? How do you handle the Product Identification?

 

Please help!  :helpplease:



ChristinaK

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Posted 25 October 2016 - 06:37 PM

I'm not in produce, but our facility is SQF certified, so maybe I can help out.

 

Here's what the code says:

 

2.6.1 Product Identification (M)

2.6.1.1 The methods and responsibility for identifying products during all stages of production and storage shall be documented and implemented. The product identification system shall be implemented to ensure:

i. Raw materials, work in progress and finished product are clearly identified during all stages of receipt, production, storage and dispatch; and
ii. Finished product is labeled to the customer specification and/or regulatory requirements.
2.6.1.2 Product identification records shall be maintained.

 

Are you using any of SQFI's implementation guides? They are extremely helpful in interpreting what the code means. Here's the guide for Module 2: http://www.sqfi.com/...uidance-7.2.pdf

 

From the implementation guide:

 

What does it mean?

To allow for effective trace back (refer 2.6.2), recall (refer 2.6.3) and stock control and rotation (refer 2.4.9), materials and products at all stages of production must be labelled and identified. How the supplier goes about this is entirely their own choice, as long as product can be identified and tracked at every stage of production.

What do I have to do?

This element is mandatory. The supplier must be able to clearly identify product upon receipt, throughout the process and when it is a finished product.

Product that is in-process may be identified in a variety of ways. The facility could use bin tags, pallet tags, colors,
product tags, etc. The facility must be able to demonstrate how the product identification system works for incoming
materials, work-in-progress and for finished product.
The finished product label needs to contain information that accurately describes the product in accordance to
customer specification and/or regulatory requirements in the country of origin and intended country of destination.
The supplier is required to prepare a procedure outlining who is responsible for maintaining the product identification
system and include in the procedure the methods used to identify product.
When shipping finished product, the supplier must ensure the product is clearly identified and that all product
identification details are accurately described on dispatch documents or otherwise included with a shipment once it
leaves the business.

 

Basically for this section, it is important that you prove that your fruits and vegetables have a way of being tracked. For example, if you track by lots, your identification system should be able to inform you of the product origin (where it came from, when it was received, etc), what happened to it while it was stored at your facility (where was it located, did it get moved, etc.), and its ultimate destination (what customer received it, when it was sent out, etc). So 2.6.1 is really about making sure that you have a system in place that would allow you to be able to track your fruits/veggies. How you track them is up to you, but you must be able to track them. As for finished product being labeled, if there aren't regulatory requirements for fruit/vegetable labeling, then you can label them however you'd like (or how a customer requests it).

 

If it may help, here's an excerpt from our recent SQF Audit Report on how our labeling requirement was met (we label everything with barcodes to track our materials through the production process):

 

The facility followed the procedure Q104 Product Identification Trace and Recall Procedure that defined the method and responsibility for

identifying product/materials during all stages of production, storage, and shipment of product. The procedure also provided guidelines with
respect to identification of secondary containers. Receiving, production and shipping records reviewed during the facility audit, as well as
and the six randomly selected production runs clearly identified product through all stages of the operation (see clause 2.2.2.2). Bar coding
was put on containers of raw materials, WIP, finished goods, clean scrap, regrind, etc. The [x] system was used to scan the bar
codes through all process steps and manage inventory.

 

I hope this helps!


-Christina

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KateG

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Posted 27 October 2016 - 05:27 PM

Thank you Christina! I wanted to make sure I wasn't over thinking this. Your response is very helpful! 



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ChristinaK

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Posted 27 October 2016 - 05:45 PM

Thank you Christina! I wanted to make sure I wasn't over thinking this. Your response is very helpful! 

 

Awesome! You're very welcome! I hope your SQF certification goes well, and don't forget to come back with any more questions!


-Christina

Spite can be a huge motivator for me to learn almost anything.




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