Week 32 Non-Conforming Materials - We've Got SALSA Sussed
Week 32 Non-Conforming Materials
This week we will discuss
Non-Conforming Materials.
Non-Conforming Materials can
come in many forms. We need to know what to do with them, no matter what stage or
condition they are in. Having a Procedure which deals with every eventuality of
a Non-Conforming Material, is the right way to achieve this. It is also a SALSA
requirement.
I will explain what you need
to think about so that you can make sure you have everything covered.
What’s coming next… Week 33 Corrective Action
Non-Conforming Materials - what do you need to show your
SALSA auditor?
Non-Conforming Material
Procedure
Quarantine Record / On Hold
Notice / Non-Conforming Material Record (or similar)
Quarantine Area
Quarantine Area
Having a specifically designated
Quarantine Area in which to put Non-Conforming Materials is a very good idea.
If you do not have the space, then having DO NOT USE or QUARANTINE tape to wrap
around the ingredient or product is another way to designate it.
The Quarantine area can be used
for all Non-Conforming Product (Raw Materials, WIP & Finished Product) where
this is possible or appropriate on your site. Separate Quarantine areas may be
necessary, such as in ambient storage, chilled storage, or high risk / low risk
areas for example.
Non-Conforming Materials come in
many forms; Ingredients, Packaging, Labels, WIP (Work In Progress) or Finished
Product.
Once you designate your Quarantine
area(s), it’s a great idea to put laminated ‘Quarantine’ posters up so that everyone
knows where and what they are. Add the locations to your documented
‘Non-Conforming Materials Procedure’ too, so that when staff are being trained,
they are also being informed.
Non-Conforming Material
Procedure
Non-Conforming Materials come in
many forms, we can split this into 3 groups:
1.
Raw Materials (Ingredients, Packaging &
Labelling)
2.
WIP (Work In Progress) products that are in the
midst of being produced
3.
Finished Product
When writing your Procedure, if
you work through each of the groups identified, you can put a Procedure into
place for each.
Raw Materials at Goods In
When Raw Materials are delivered
to you, they are checked at Goods In. We talked about the Goods In process on
Week 13 of We’ve Got SALSA Sussed, if you want to refer to it.
If there is a problem with the ingredient
at Goods In, then you may want to reject it. You can then contact the supplier
who should deal with it and send replacement to you. However, if you do not get
direct supply delivered by your supplier, it is not always as easy as that. The
delivery could come through a courier who will not deal with a return,
therefore you will have to accept the delivery and then deal with it yourself.
If you have to accept a ‘defect’ ingredient
into your facility, which, for example could be badly damaged packaging which
has been pierced and therefore could be contaminated, you cannot use it. You
need to have an area to quarantine the ingredient so it does not accidentally
get used.
Raw Materials in Storage
Ingredients (or packaging) might
be in storage when you discover they are Non-Conforming. You may put them to
waste immediately, however you need to record amounts so that they can be
accounted for.
If the ingredients are infested
with pests, they will definitely need putting to waste immediately.
However, if there is a problem
such as, finding Non-Organic ingredient, when it is supposed to be Organic,
then it cannot be used as it could make your product not
legally compliant. It might be that the ingredients are out of date,
therefore they need to be quarantined, so that they are not accidentally used. Or
you find labels which are an old version (with incorrect allergens,
ingredients, weight etc), you would have to put these ingredients / packaging /
labelling On Hold, in Quarantine, so that it does not accidentally get used.
WIP (Work In Progress)
WIP are Products in the midst of
being made. If you are producing a product which you realised you have put a kg
salt in by accident, when it should have been sugar, then you would have to put
it to waste. It might be that you need to put it on hold first until someone
can remove it, which is where the quarantine area comes into use again. It is
more likely that you would probably put it straight to waste.
However, another example might be,
whilst you were weighing out and adding ingredients to a cake batter in a
mixer, that you find that you have lost your blue plaster, or metal detectable
pen you were just using. You may want to put the mix On Hold in Quarantine,
until an investigation has been performed to find it before progressing with
making the product. If found elsewhere, you can remove the mix from quarantine
and continue with making your product. Or, if it is in the mix, or you cannot
find it at all, the mix would have to be put to waste.
Finished Product
Finished Products may have to go On
Hold in a Quarantine area for a number of reasons. An example is they could
have been labelled or coded incorrectly. They would have to be put into
Quarantine to prevent them being sent out as ‘good product’ until they can be
relabelled / coded.
Another example is that the metal
detector could have broken down. You would have to wait for it to be repaired
before putting the product through it before it can be sent to the customer.
Meaning the product should be On Hold in the Quarantine area.
Quarantine Record / On Hold
Notice / Non-Conforming Material Record
Whatever you decide to call the
record; Quarantine Record / On Hold Notice / Non-Conforming Material Record,
you need to record why the item is On Hold. I always advise to use a form which
is bright and will get noticed to attach to the Non-Conforming item. An example
of an On Hold Record.
I would also advise keeping all of the On Hold notices, to show evidence of what happened. Even if they are taken off hold, as and when they are found to be OK to use (i.e., no blue plaster or metal detectable pen was found in the mix, it was found elsewhere!), if we keep all of the records, we always have the evidence of what happened.
It might be appropriate to
complete an Incident Record as well.
An Incident Record will provide a
place for you to document your investigation into the Non-Conforming Material. We
will go into Incident Records in the coming weeks, when completing the section
about ‘Incidents, Recalls & Withdrawals’.
As always, I am more than happy to
answer any food safety related questions, whether they are SALSA related or
not. Get in touch!
Be careful and stay safe!
Ruth
Ruthshawconsultingltd@gmail.com
07732
966 836
Comments
Post a Comment