SQF ed. 9 2.4.4.5 - Retention Samples in a bakery

Hi, the SQF edition 9 code reads the following: 2.4.4.5 Retention samples, if required by customers or regulations, shall be stored according to the typical storage conditions for the product and maintained for the stated shelflife of the product. Does this mean I must retain shelf life samples? Or is it an option? Neither my customers require it. Does FDA require it? Thanks

Neither require it!

While it's not a specific requirement, it can be helpful. In my experience it is rare that they're needed, but it could make a big difference in some situations for your company. 

It can be useful to have a sample of product on hand in case there were any complaints about mold growth or other spoilage. If you're holding the product in appropriate storage conditions, that can be helpful in your investigation to determine if the spoilage was due to product formulation/scaling issues or at the customer level for poor storage conditions. 

I haven't had this happen personally, but it can be advantageous to be prepared for a customer claiming that product was contaminated or hazardous to health. This example might be out there, but imagine if there was an investigation for food-borne illness that was traced back to a customer's establishment, and your facility by extension was a component. Say, a sandwich or burger. Having a retention sample on hand for analysis could be crucial to either proving your innocence (or guilt). It could be what differentiates the responsible party for the outbreak (manufacturer or the restaurant). 

This of course is more helpful for some products over others and I'm sure there's more applicable examples than what I can think of right now. That's the logic behind it. 

Has anyone had a positive or negative experience with retention samples? 

For me, they can be a pain to keep organized and to regularly dispose of the expired samples. However, I have some peace of mind from knowing I have a sample of everything we've sold in case anything goes horribly wrong. 

Overall we have found keeping retention library samples from each batch of finished product very helpful in dealing with consumer complaints for visual confirmation and/or analysis.

We currently retain all samples for total shelf life + 4 months past when they are deregistered from the sample log and destroyed.

Likewise we also retain samples of all raw materials against a risk based sampling plan.

The main issue is storage for potentially a large number of samples over hold time. The quantity you keep will be dependent on the product type, how it's packaged, storage conditions required and the size of the sample you have determined to keep that will be representative of a batch/lot.

We are certified to FSSC22000 and Organic production standards.

The only time I kept retention samples was in Cannabis, and that was due to regulatory requirements and in pickling (due to the extremely long shelf life)

Yes, it's a pain to manage, and if you produce 100s/skus a week, can turn into a full time job to pull, log, store and remove them

The only time I kept retention samples was in Cannabis, and that was due to regulatory requirements and in pickling (due to the extremely long shelf life)

 

Yes, it's a pain to manage, and if you produce 100s/skus a week, can turn into a full time job to pull, log, store and remove them

Yes agree not always an easy task especially with a large number of sku's. Much easier if you have a long shelf life/stable product.

We keep samples for the shelf-life of the product. They've been the most helpful for quality issues we'll receive. Usually the complaint is taste, size of the vegetables, not getting enough of an ingredient, etc. Having a lot of sku's does make it more difficult. It helps that many of our products have a short shelf-life.

Another reason to take a sample : today I sent in a comment/complaint about a frozen vegetable item I purchased. It was supposed to have marinara sauce on the frozen vegetables - there was no sauce. My guess - they don't take samples or it would/should have been caught.