Daniela Verhaeg | Consumer complaints: demonstrating due diligence

Daniela Verhaeg, marketing manager, Mettler-Toledo Safeline X-ray, explains how to demonstrate due diligence.

Daniela Verhaeg LR

Despite being proactive and quickly instigating a product recall after receiving consumer complaints about glass shards in one of your top-selling food products you may unfortunately, still receive negative media attention about your brand. In addition, food safety authorities will probably contact you in order to ascertain how the contamination incident happened. Internally, within your own organisation, you may have suspicions that the contamination did not take place while the product was under your care, but happened after it left your facility, deliberately carried out by a dissatisfied consumer. However, how do you demonstrate that you have done everything you can to uphold product safety and that you are not responsible?

There are a number of things you need to do to prove you have done all you can to promote safety in the event of a contamination incident and a product recall. You need to have as much information available as possible about your production line performance and the products that have been processed on it, including product inspection data regarding contamination, seal integrity and other quality checks. This will make the food safety investigators’ job as straightforward as possible to help prove to them that you have been operating within safety guidelines and, if necessary, that the contamination did not occur while the products were under your care.

Having advanced x-ray inspection technology installed on your production line that complies with local, international and retailer safety requirements can ensure the risk of physical contamination incidents occurring are minimal. Not only can they detect and remove even minuscule contaminants during production, but they can also inspect for seal integrity at the final packaging stage, so you can be certain that your products are contaminant-free and not at risk of accidental contamination after they have left the factory floor. Crucially, they can also help facilitate the demonstration of due diligence for you and any investigators.

Systems that have innovative data monitoring features can record and store vital information regarding contamination detection and seal integrity inspection, including the number of conforming packs and rejects, all linked with batch and lot numbers. This makes it as simple as possible to show that every part of the production line has been operating according to food safety standards. Most importantly, by allowing you to trace products back through the production line, they can either help you locate the source of contamination or even demonstrate that the contamination incident could not have occurred while the product was under your care.

It is possible to link modern x-ray inspection systems to a broader data monitoring network, providing even greater storage capabilities for the archiving of records for a longer period of time – something that will be of importance when it comes to long-life products, such as tinned foods. This allows the collection of food safety key performance indicators from across the production line to be stored indefinitely in one easy-access location, facilitating later analysis in the event of recalls of products that left the production line years before.

Current safety guidelines, such as the British Retail Consortium (BRC) Global Standards Version 7 in effect in the UK, or the International Featured Standards (IFS) Version 6, in place in France, Germany and other main European countries, do not specify a minimum length of time for which records must be kept. However, by archiving records for as long as possible, you can ensure that you always have the relevant details to hand in order to demonstrate that you have done your duty to safeguarding products – and the consumer.

Another way to prove due diligence, in the event of a contamination incident, is to optimise the traceability of your products through the supply chain. Track and trace technology connected to your x-ray inspection systems can make a note of the lot numbers of each product as they pass by, linking them with batches and with the relevant inspection information. Installing these technologies at the end of the production line can help you guarantee the products are of the highest possible quality and contaminant-free at the point when they leave the factory for the retailer.

To facilitate tracking of packs within the production process and help identify the source of any contamination incident, you should install product inspection systems at each Critical Control Point (CCP) on the line. These are the stages on your production line at which contamination is most likely to occur and can be determined during a Hazard Analysis and Critical Control Point (HACCP) audit of your processes. Checking your product at each CCP can increase the likelihood that contaminants will be detected and will better enable you to pinpoint the contaminant source so you can undertake corrective action. It can also, most importantly, demonstrate unquestionably to food safety authorities that the contamination did not occur at any stage on your production line, but later, either under the retailer’s care or that of the consumer who made the complaint.

When dealing with the misfortune of a product recall event, it is vital that you are able to demonstrate that you have done everything required to uphold product safety, and that you are innocent, if you are not responsible for the incident. The best way to achieve this is by exceeding regulatory requirements, through the installation of product inspection equipment at each CCP and by carefully archiving inspection records. Doing so can help you show food safety authorities and your customers, the retailers, how much you are committed to the safety and wellbeing of end consumers, and ensure you are not liable for any damages.