How to avoid mislabeling of packaged foods: Page 2 of 2

By Gary Kestenbaum in Food Safety on May 01, 2017

Cautions regarding identify job descriptions and qualifications

You wouldn’t assign the accountant to install a cartoner, nor would you ask the continuous improvement engineer to perform analytical chemistry. Why assign an underqualified, but available resource to make decisions and execute tasks which might result in a critical labeling or product communication failure? In the food industry, a series of expert sensory analysis protocols control process and qualify or disqualify judgements. Shouldn’t expert visual analysts or data entry technicians be subject to criteria for qualification and execution?   

Don’t assign critical observation and analysis of copy, alphanumerics and label choice to an unqualified, overworked resource. Match job descriptions with skilled resources. 

  • Create a table of identification, information and communication task responsibilities by group or step as identified by the cross-functional team.
  • Create a list of qualifications for each grouping using the list below, adapted to each unique challenge.
  • Responsibilities for product, material and packaging identification is broad. Qualifications based on expectations and requirements are likely more extensive than you considered.

    Identification professionals” competencies can be bucketed within three competency categories and may include some or all of the following:

    • Skills
      • Reading Comprehension and Technical Writing
      • Analytical Thinking (logic, reasoning, problem solving).
      • Listening (what colleagues are saying).
      • Effective Speaking (conveying information effectively).
      • Monitoring and Assessing and Evaluating Performance.
      • Judgment/Decision Making: assessing costs/benefits of effective corrective solutions.
      • Time and resource Management (one's own and colleagues or subordinates).
      • Applied Learning and speed of application.
      • Complex Problem Solving.
      • Coordination of actions and activities.
      • Influencing, Persuasion and Negotiating Skills.
      • Social Perceptiveness and Orientation, i.e. playing well with others.
      • Learning and Training - Selecting situation-appropriate methods and procedures.
      • Systems Analysis – Evaluating how changes in conditions, operations, and environment affects the outcome of the system or processes within.
      • Creative Design and Operations Analysis (connecting objectives with requirements).


      • Knowledge
        • English and other Languages: structure, spelling, content, meaning and grammar.
        • Functional Knowledge of Location and Industry Communication and Nomenclature.
        • Computers, Electronics and Technology including applications and configuration.
        • Clerical and Administrative skills.
        • Targeted Education and Training: Knowledge of process-specific principles.
        • Laws and Regulatory process knowledge relevance and how/where to access. 
        • Corporate and facility History and Culture.


        • Trait
        • Attention to Detail and Care.
        • Dependability, reliability and Responsibility to obligation fulfillment.
        • Customer Service Orientation (always looking for ways to “satisfy the customer”).
        • Initiative to undertake responsibilities and challenges.
        • Adaptability/Flexibility to change.
        • Innovation, Creativity and Ideation to solve problems.
        • Achievement/Effort and Ownership
        • Persistence in the face of obstacles.
        • Stress Tolerance and Criticism Acceptance (dealing calmly and effectively with high stress situations).
        • Cooperation with and concern for others
        • Independence and execution with little or no supervision.
        • Integrity, honesty and ethics.

    This is not to suggest that every person in the process chain needs to excel at all 35 competencies, but it is a “best practice” to consider which of the 35 are critical to the successful execution of each job, responsibility or task relating to information selection, creation, identification and selection.

    Once each job objectives is matched to a description and qualifications:

    3. Determine whether there is a resource currently assigned to each task or not.

    4. Fill in names or functions and identify gaps.

    5. Compare expectations against candidate qualifications.

    6. Adjust obvious mismatches.


    When qualified professionals are chosen and assigned, the resources must collaborate and consider (at least) policies and procedures of the end objectives, challenges of the individual facility, assignment of risk levels and expected frequencies, known or expected gaps, prior calamities and similar subject matter. Scheduled discussions and personal ownership should pave the way for practical upgrades and process improvements.

    Executional considerations and final thoughts

    There is no single set of protocols to use for Identification management. However, consideration of the previously listed competencies, or an adaptation of same, may help your organization in resetting objectives and then comparing the complexity, challenges, resourcing and other characteristics of those objectives against your existing process.

    Ponder a few general concepts when creating processes to control critical product information and identification:

    • One set of eyes isn’t nearly enough. Often, neither is two.
    • If multiple human visual observations fail to find a defect, error or omission, is there a process change that may reduce that occurrence risk? If no, is there a redundancy, preferably technological, which can be implemented?
    • Is the identification, information and communication safety team tasked with analyzing monthly labels/copy etc. defects, assigning causes and ideating corrective actions? 
    • When was the last time a food safety calamity was caused by too much training?

    Reassess the process, redesign it, resource it, train it, implement it, validate it and audit it. Your facility will unquestionably benefit from the process improvements!

    Gary Kestenbaum has 40 years’ experience in the food and packaging industries, 6 as a supplier with National Starch, 18 as a product developer with General/Kraft Foods and 15 as a packaging engineer and developer with Kraft. As senior food packaging safety consultant with EHA Consulting Group, Kestenbaum provides guidance on packaging safety and suitability-related projects for raw material manufacturers, converters and associated supporting professionals. He can be reached at [email protected] or 410-484-9133. The website is

    Filed Under:
    By submitting this form, you accept the Mollom privacy policy.
    500 characters remaining