An Ounce of Prevention

Whether it’s a food safety snafu, a lack of consistency from product batch to product batch, or something else, an issue on the quality assurance/quality control (QA/QC) side can be time-consuming to resolve and damage a brands reputation along the way But retailers, most often not able to directly monitor manufacturing operations tied to their store brand products, could take a number of steps to avoid problems here.

ID risk areas

A good starting point for retailers is identifying and understanding the areas in which QA/QC-related shortcomings commonly occur. According to Alan Perlman, business development director for the Consumer Products Division of Ann Arbor, Mich.-based NSF International, one common misstep on the product quality side occurs when products tested in a test kitchen don’t match the final manufactured product — or when a product produced by multiple manufacturing facilities, using the same formulation, somehow ends up differing from facility to facility. Other common store brand-related missteps on the part of retailers, he says, include:

• Not reviewing products for quality characteristics at the end of product life.
• Writing unclear or difficult-to-understand product label directions, instructions and/or warnings.
• Not transit-testing products to determine whether or not shipping will impact product quality.
• Not conducting consumer sensory panels, or not conducting them properly.
• Allowing a supplier to make product formulation changes without notification.

Yet another common shortcoming centers on retailers not knowing exactly what they want a product to be in terms of positioning, says Jerry Kelly, verification services (VS) client services specialist for UL LLC, Northbrook, Ill., preventing them from developing a well-defined specification for that product.

James Cook, food scientific and regulatory affairs manager for SGS Consumer Testing Services, Fairfield, N.J., agrees, noting that problems run the gamut from insufficient specifications to meaningless specifications.

“For example, sensory specifications routinely state ‘typical green bean flavor, color and texture,’” he says. “Green bean varieties, harvest locations and weather conditions vary the flavor, color and texture.”

Failure to keep up with specification changes also can be an issue for retailers that are trying to match a specific national brand, notes Ann Behen, VS technical consultant for UL.

“They can change over time, and if they don’t keep up with modifying those specifications, then the products aren’t going to meet the spec,” she says.

Heena Patel, technical director, supply chain food safety audit services for Emeryville, Calif.-based SCS Global Services, points out that product quality issues often occur during product changeover. If a retailer relies on a private brand manufacturer that produces high quantities of products, “one small hiccup in the changeover process” can escalate greatly when that changeover is repeated myriad times.

“Poor training is the primary culprit when it comes to quality mistakes,” she says, “and is often compounded by a lack of communication between managers and production workers, and a lack of supervision on the production floor.”

And although most retailers have programs in place to evaluate and deal with product quality concerns, some of them do not have programs that allow them to routinely do so at the store level, says Steve Oswald, senior account manager for Chicago-based Silliker Inc.

“The reasons behind the absence of such programs vary from cost to available resources,” he explains.

And on the food safety side, Cook notes a tendency for both retailers and suppliers to focus on the overall score in relation to facility audits instead of examining the non-conformances and determining whether or not proper root cause analyses and corrective/preventive actions have been performed.

“Food and food ingredients are variable because they are impacted by nature, making testing and inspection vitally important,” he stresses. “At the product testing and inspection stage, retailers and suppliers tend to sample at a rate lower than required for proper determination of compliance. In addition, not every production lot is tested and inspected.”

Other common food safety shortcomings, Perlman says, include:

• Illegally packaged or mispackaged products. For example, if a known allergen is left off the ingredient list, the result could be allergen issues — potentially even fatal reactions — and recalls.
• Misleading marketing claims. Such claims often reflect a lack of understanding of legislative requirements or allowed terminology.

Be proactive with quality initiatives

Retailers also could take a number of steps to avoid product quality issues. For starters, they could work with suppliers to develop meaningful specifications designed for both the product and the equipment producing it — and adhere to them, Cook says.

“Establish a color standard for relevant products,” he adds. “Use sensory terms whether positive or negative such as sweet, not bitter, crisp, tender, not woody, not fibrous, etc., for flavor and texture.”

When trying to match a national brand, Perlman advises that retailers and their suppliers “take multiple codes from multiple regions to ensure consistency.” The retailer also should be present at the first production run to ensure the product meets standards.

Perlman also recommends that retailers and suppliers develop and sign off on clear quality attribute sheets for each product that include photographic standards.

“Products should then be evaluated against these criteria,” he says. “A detailed ‘product blueprint’ will help ensure the right product is made each time.”

Training related specifically to product changeovers and their complexities also can be helpful in preventing quality-related issues, Patel notes.

“Verification of labels and product specifications is also important in order to make sure the retailer is getting exactly what it asks for,” she adds. “I am a big proponent of peer review.”

As for sampling and inspection, Cook advises a statistical approach that is less about compliance than it is about recognition of noncompliance.

“Results that are out of specification must be evaluated to determine the reason,” he says, “to develop a corrective action plan as well as a preventive action plan that will stop the noncompliance.”

Retailers could link their existing sales volumes, consumer complaints and product quality risks to create a customized program that monitors at-risk products more frequently, Oswald says.

Finally, retailers and their private brand suppliers will want to consider using outside independent third-party laboratories and QA companies for ongoing evaluations of a product line, says Brett Lafrance, VS North America sales director for UL. These companies bring an unbiased mindset to the table and could help detect when a change in the product occurs.

“Instead of one initial test or a review of an audit report, it’s an ongoing program where sampling is taken continually from a manufacturing facility or maybe even purchased at shelf and tested on an ongoing basis,” he says. “Should a change be detected, that company can then investigate through corrective action and preventative action and determine the root cause of the problem and then help to solve that root cause.”

Food safety: Think beyond certification

To help ensure the highest level of food safety, the majority of retailers now require their private label suppliers to be certified to a Global Food Safety Initiative (GFSI) scheme, Oswald notes. Efforts here can go a long way to enhance food safety, but retailers also need to look beyond certification.

“From time to time, international suppliers/manufacturers may overlook or not be aware of export regulations and use processes and approved ingredients that are not approved by the Food and Drug Administration,” Oswald says. “Increased due diligence is needed by these companies to [ensure] that their products conform with industry best practices and regulations.”

During the evaluation process, therefore, retailers “should strongly consider” performing product-related risk assessments of their suppliers, he says.

“The assessment should include, but not be limited to, GFSI certification, product risk reviews [and] challenge studies, as well as regulatory and nutritional label reviews,” Oswald adds.

The retailer needs to ensure the supplier has adequate capacity to meet its needs, too.

“A lot of times you have very aggressive small to medium manufacturers that are looking to grow their business,” Kelly says. “And a lot of times, when they are trying to increase that production from A to B, they’ll encounter challenges that they don’t foresee.”

Continuous monitoring and clear communication also are essential once a retailer contracts a store brand supplier, Patel notes.

Speaking of good communication, a solid specification is paramount, Kelly says, because that’s what lays the groundwork for food safety.

And when it comes to facility audits, retailers and suppliers need to comb through the whole report, not just the summary page, Cook points out. That review should include an examination of all of the non-conformances to ensure they are minor in relation to food safety.

“They must have a proper root cause analysis, corrective action — not correction — and preventive action plan,” he says. “For any critical non-conformances, the facility needs to resolve the issue and be re-audited.”

Also helpful, Cook notes, is a comparison of nonconformances to previous audit reports. If the same issues are occurring over and over, that suggests “a problem with the root cause analysis, corrective action or preventive action plan.”

Testing and inspection for food safety parameters, using a statistical sampling plan, are critical, too — and for every product lot. They can be performed internally or by a third party, Cook explains.

A little common sense also goes a long way. Retailers and suppliers, for example, should employ or contract copywriters who have an understanding of relevant regulations, Perlman says.

“Graphics staff are not regulatory experts!” he adds.

Other advice Perlman offers includes using a web-based platform with stage gates, training suppliers and retail employees on regulatory requirements and legislative changes/updates, and critically examining existing products and packaging to pinpoint inconsistencies and other issues.

“It’s tough to self-assess,” he notes of the product and packaging assessment, “so utilize independent third-party expertise to conduct the review. As part of the review, include the key competitors so you are fully cognizant of what is going on in the market.”

Ultimately, retailers also should be prepared for a food safety-related recall.

“Practice makes perfect,” says Brandon Nauman, food testing project manager for SCS. “Conducting announced and unannounced mock recalls helps retailers build on their strengths and identify weaknesses. It can be hard on suppliers at first, but it can be necessary in forging a better relationship between suppliers and retailers and avoiding mistakes in the future.”

“Poor training is the primary culprit when it comes to quality mistakes.”
— Heena Patel, technical director, supply chain food safety audit services, SCS Global Services

Continuous monitoring and clear communication also are essential once a retailer contracts a store brand supplier.