Food packaging safety expert Gary Kestenbaum offers advice on identification process objectives, defects, review and suggestions for process improvement related to product labeling and identification failures for food products. Is your company aware and prepared?
Misidentification, a critical process category in the food information supply chain, represents a huge, ongoing, unnecessary and eminently correctable calamity in the food industry. Misidentification includes defect types such as mislabeling, erroneous or missing copy, intermingling of materials, graphic design/printing errors, program entry errors and related defects. Allowing this category of defect to reach market occurs across the full spectrum of food and packaging products including raw materials, components, intermediates and consumer products.
Repetitive human safety-related error and omission defects are often facilitated by under-consideration as to severity and harm, under-resourcing in comparison to other safety-related risk types, or, simply, weaknesses in the process in need of review and redesign. Language in information-based “lessons learned” usually suggests that redundancies, process improvements, resource upgrades, continuous training and upgrades to the inspection process would have mitigated risks. Summaries often acknowledge funding and resource limits, offering the mea culpa “we targeted our resources on the safety of the food and then packaging/labeling defects flew under the radar.” Responsible organizations follow “lessons-learned” exercises with a process review, culminating with a rewiring in kind.
Understanding and classifying identification defects
There are many types of misidentification-related defects within the broader category which may ultimately impact the consumer, manufacturer and intermediate user. Some of the most common include:
- Omitted details in written regulatory, food safety or product data documents, such as allowable and suggested usages and applications, regulatory references, etc.;
- Errors or omissions on the package or container identification labels or printed copy (right product, wrong description or wrong product, right description);
- Programming, configuration or data entry errors within labelers, bar code readers and related electronic hardware;
- Specification or test data errors or omissions;
- Product/item naming and identification similarity (appearance and identification graphics of two or more products are virtually exact);
- Code-dating, manufacturing and related trace and recall data errors;
- Design errors (graphic designer or programmer given the wrong details to add or misrepresented/misunderstood the details;
- Unreadable alphanumeric characters due to substandard print quality or faults;
- Intermingling of products in package such as when the inner package or product description doesn’t match outer package description; and
- Shipper/unit load coding errors.
From a food safety standpoint, these defects are viewed similarly to those in the food (edibles) production chain. If one step is weak or prone to failure, the entire downstream process and users are exposed to risk and harm.
Clarifying objectives in policy
Begin the process by creating a policy or reviewing the language in your existing policy, describing the safety, quality and financial importance of the identification, labeling, copy, graphics and application/selection processes. Clarify the need for accuracy and explain the harm associated with failure to successfully accomplish those tasks.
Procedures connected to the policy should include clear chain of oversight, responsivity and execution. Steps should include creation of a committee or team, whose main objective is to review or, in the absence of existing, create job descriptions and qualifications for each person or group tasked with any process related to identification, labeling, selection, application or oversight of same, including:
- Graphics and alphanumeric text development (hardware, configuration and data entry);
- Technical content review(s) for errors, omissions or confusion risks;
- Physical review processes including quality and accuracy;
- Selection and application accuracy at the manufacturing or distribution level;
- Review and oversight redundancies;
- Ongoing 2nd or 3rd party process audits to validate effectiveness;
- Team review of defects and actionable events; and
On face value, this may seem arduous or frivolous, but consider that eliminating one market withdrawal or recall would pay for multiple years of implementation costs.
In other words, treat the process as what it is: a hazard to consumer safety, your productivity, profitability and reputation.
Next: Cautions and final thoughts