FDA regulation for food and beverage labels

Q: I have been asked to do a quality audit of a label manufacturer whose products are used on beverages and food packaging. They are currently asking to be audited using 21CFR211 (pharmaceuticals). Is there another standard that is more appropriate for their product?

A: 21CFR211 is the FDA regulation for cGMP for finished pharmaceuticals. This regulation does not apply to the labeling of food and beverages. The proper FDA regulation is 21CFR101. I suggest that you first start on the FDA web page on food labeling and nutrition.

John G. Surak, PhD
Surak and Associates
Clemson, SC
A member of Stratecon International Consultants
www.stratecon-intl.com/jsurak.html

Related Resources: 

Browse the free, open access content below, or find more in the ASQ Knowledge Center.

Can Do: An effective overseas food-safety audit is possible—if you know what to expect,” Quality Progress

The challenges inherent in food-safety audits become more problematic when foreign suppliers are targeted. Language and social barriers, as well as varying compliance requirements, are the biggest hurdles. With a careful plan and an emphasis on keeping things simple, auditors can overcome the challenges. Read more.

Kano’s Theory of Attractive Quality and Packaging,” Quality Management Journal

The role of consumer products packaging has moved beyond that of merely protecting the contents to a more vital role as a marketing vehicle. This raises the issue of how packaging should be designed to relay an association with high quality to the consumer. An empirical investigation based on Kano’s theory of attractive quality was conducted to determine how 24 quality attributes of packages are perceived by customers. Read more.

Explore the ASQ Knowledge Center for more case studies, articles, benchmarking reports, and more.

Browse articles from ASQ magazines and journals here.

Dock to Stock

Suppliers, supplier management

Q: I have been tasked with implementing a dock to stock policy. Does an expert have any advice or information to share towards forming a dock to stock policy?

A: To begin, here is a brief definition of dock to stock (DTS):

Dock to stock is a receiving method whereby materials are delivered directly to point of use (storage or manufacturing), skipping the normal receiving inspection.

For most organizations, parts which are given a DTS status are those which have been “proven” to be compliant. It is common practice to perform a receiving inspection on the parts for a minimum of five deliveries (some companies choose 10).

After a supplier has proven to deliver a compliant product five times, that individual item/part number is given DTS status. It is then general practice for production/assembly departments or line personnel to verify compliance as needed. If a product is found to be noncompliant, it is put on a contingency list and must prove its validity again — usually through five to 10 compliant shipments before it is returned to DTS status.

Keep in mind that the DTS process is rarely used in some industries/companies. For example, a company certified to ISO 13485 (medical devices) would not use DTS due to FDA regulations — here’s an excerpt from 21 CFR 820.80 (b):

“Receiving Acceptance Activities: Incoming product shall be inspected, tested or otherwise verified as conforming to specified requirements.”

In short, determining how many acceptable shipments to qualify a supplier for DTS status is up to the company. Requesting a certificate of compliance with each shipment can tend to encourage a supplier to ensure their own quality, as does a yearly audit of the supplier’s facilities (if appropriate).

I hope using the guidelines above will help lead you toward your goal.

Bud Salsbury
ASQ Senior Member, CQT, CQI

Related Content:

Browse the free, open access resources below, or find more in the ASQ Knowledge Center.

Chinese OEM Reduces Returns With Improved Product Testing, ASQ Knowledge Center case study

When Continental Automotive Systems, Tianjin, China, began producing an electronic component known as the silver box, the return rate was more than 1,200 parts per million (ppm), versus a goal of less than 100 ppm. A Six Sigma improvement team used quality tools including trend charts, Pareto charts, and cause-and-effect diagrams to analyze the failure modes for the reported defects, finding that many were not being covered by product testing processes. Read more.

Cost-Effectiveness Based Performance Evaluation for Suppliers and Operations, Quality Management Journal

This research establishes a cost-effectiveness based  performance evaluation system for suppliers and operations. The purpose is to provide a methodology for “integrating supplier and manufacturer capabilities through a common  goal, profitability improvement, based on lowering the cost of purchased materials.”  Read more.

Expert Answers: Stock and Standards, Quality Progress

The advisability of implementing dock-to-stock is discussed. Read more. 

Ask A Librarian

Is it Legal to Require Certification to an ISO Standard?

Contract, requirement, legal, standard

Q: Can a contract include a requirement stating that the manufacturer of the materials to be installed as part of the job must be ISO 9001 and ISO 14000 listed? My question is in reference to a contract I received that is requiring this.

A: In general, contracts between business entities are enforceable unless they violate laws or are contrary to public policy. Private businesses entering into commercial contracts have a great deal of freedom in establishing contract terms.

One of the common uses of ISO standards is to clearly delineate requirements in commercial contracts.   This can, and often does, include requirements for third-party certification of suppliers to ISO 9001-2008: Quality management systems–Requirements and/or ISO 14001-2004: Environmental management systems – Requirements with guidance for use.

This requirement is usually met by providing a copy of the certificate issued by a third-party certification body (registrar) that lists the name of the organization certified and the scope of the certification.

Based on the information provided along with your question, it appears that the question actually relates to a material specification that was included as part of a request for proposal (RFP) from a governmental entity. Note: the contract has not been included with this post to protect the anonymity of the questioner and the governmental entity.

The authority of governmental contracting officers is more limited.  They must comply with applicable purchasing statutes and regulations.  Whether or not a requirement for certification to ISO 9001 and/or ISO 14001 is permissible would be determined by reviewing these contracting rules.  These rules also often provide mechanisms for contesting the award of a contract if it is believed to be unfair.

There are often opportunities to request clarification of information included in a government-issued RFP. This may be something to consider in this situation since the requirements in this RFP appear to be unclear, such as:

  •  There is no comprehensive “list” of certified companies so there is no mechanism for a manufacturer to be listed.
  • There is no ISO 14000 standard.  There are over 20 different standards in the ISO 14000 family – each with a different number.  I assume the RFP is referring to ISO 14001.
  • It is not clear which of the materials specified in the contract must be manufactured by an organization that is certified to the ISO 9001 and ISO 14001 standards.

(Note: the contract has not been included with this post to protect the anonymity of the questioner and the governmental entity).

I hope this helps.

Thea Dunmire, JD, CIH, CSP
Chair, ASC Z1-Audit Subcommittee
ENLAR Compliance Services, Inc.
Largo, FL
www.enlar.com

Related resources:

Explore the content below or find more in the ASQ Knowledge Center.

“Quality Improvement through Proactive Contracting: Contracts Are Too Important to Be Left to Lawyers!”

by Helena Haapio Annika Varjonen, paper presented at the World Conference on Quality and Improvement (ASQ members only content)

Preventive law is the concept that legal opportunities must be identified early to take proper advantage and that legal problems must be detected early so that there are no negative surprises. Contracts can be used as preventive tools that avoid most such surprises. A vital contractual tool is the contract review, which the ISO 9000 standards identify as a device for ensuring that a supplier has the knowledge and capability for meeting a customer’s requirements. Read more.

Managing Contract Quality Requirements

by C. Robert Pennella, ASQ Quality Press

This book is for anyone who prepares contract quality requirements for a supplier, is a supplier, or is affected in any way by a contract. Readers will learn how to establish and implement contract requirements effectively; identify and resolve actual and potential contractual problems; preclude overlapping of administrative efforts; reduce unanticipated costs associated with errors of omission; and be better prepared for the administrative application and final outcome of contract quality requirements. Read more.

Career Corner: Has Information About Quality Become a Liability?

by Diane Kulisek, Quality Progress (open access)

In this career corner column, the author provides recommendations for approaching quality issue resolution in today’s complex legal landscape. Read more.

Explore the ASQ Knowledge Center for more case studies, articles, benchmarking reports, and more.

Browse open access content from ASQ magazines and journals here.

Z1.4 Split Sampling

Chemistry, micro testing, chemical analysis, sampling

Q: I have two questions about Z1.4-2008: Sampling Procedures and Tables for Inspection by Attributes.

1. Does the plan allow one to “split” sampling plans among multiple items, or is only one item per plan intended?

2. The plan states a 95% confidence level, which means the findings of the sampling will statistically show that the findings (or number of defects) will be consistent with the findings of the entire inspected lot. So, if we split the sampling, how can you determine what happens to the confidence level?

A: Thank you for submitting your question to ASQ’s Ask the Experts Program. Answers to your inquiries follow.

1. In attempting to answer any given question, one needs to understand the question with respect to its gist and terms used.

Z1.4 uses the term “unit” to represent an individual “product” entity (unit here can represent a discrete fairly simple product, such as a bolt or nut), or it can represent a complex product (such as a computer, or a large piece of machinery, or even a square meter of cloth or other material, a length of wire or other material, etc.).

It is assumed here that the use of the term “item” in the question refers to a “unit.” It might, however, refer to a quality characteristic, and the explanation given here will attempt to explain either case.

Now, units can have a single principal quality characteristic or they can have many different quality characteristics.

Z1.4 allows for some of these quality characteristics to be of greater importance (severity for example, with respect to quality and/or economic effects) than others, whereby separate sampling is applied to each group with different sampling parameters (such as sample size, acceptance number, lot size). Hence, units with a single quality characteristic can be checked by sampling via Z1.4 and units with multiple quality characteristics can be checked by sampling via Z1.4.

In each case, the chosen Acceptable Quality Limit (AQL) and what it stands for applies to whatever is included in the inspection made on each unit. It is also assumed that this separate handling of units and quality characteristics is what the question means with respect to the term “split.”

Furthermore, it should also be understood that sampling inspection can be conducted with respect to two distinctly different statistics. One is the number of nonconforming units found in the sample. These are sometimes referred to as “defectives.” The second is the number (sum) of nonconformities found on all units in the sample, where any given single unit can have multiple nonconformities. These are often referred to as “defects.”

A “nonconforming unit” is defined as a unit with one or more nonconformities (defects) — but counted only as one “defective” unit. A “nonconformity” is any departure for any quality characteristic being considered in the inspection of each unit. In Z1.4, one can use either statistic as desired. The choice is largely dependent on the nature of product units and the reason for doing the sampling inspection — whether it is to control or oversee defective units or to control or oversee defects.

In the tables of Z1.4, note the top line above the range of AQLs: “Acceptance Quality Limits (AQLs), Percent Nonconforming Items and Nonconformities per 100 Items”. It should also be pointed out that Z1.4 is intended to be a sampling scheme or system, not just a selection of a given sampling plan. Please review the standard and any number of excellent books available on sampling inspection covering Z1.4, ISO 2859, and etc.

2. If one examines the Z1.4 standard from cover to cover, one will not encounter the term “confidence level.” Z1.4 contains no confidence intervals (or levels) related to any of its features.

Furthermore, the 95% figure is a very general figure associated with the expected “probability of acceptance” at the designated (selected) AQL. This is NOT a confidence level! In fact, the AQL is NOT a statistic!

Setting an AQL is generally an agreement/negotiation process between the customer and supplier. It is more of an index. Essentially, it refers to a level of nonconformity that is generally “acceptable” — a value of 0 being desired of course — but otherwise, a compromise figure.

And it is not by any means a constant, as can be seen by examining the Operating Characteristic (OC) Curves for the various code letters A through R using the same AQL in every table.

For example, for an AQL of 2.5% with the code letter C plan, incoming quality p must be 1.03% for Pa to be 95%, and Pa at 2.5% is less than 90%; for the code letter F plan, p must be 1.80% for Pa to be 95% and Pa at 2.5% is between 90% and 95%, etc.

If confidence intervals at chosen levels are desired for any given sampling plan, one most resort to the theory and methodologies of statistical inference with the available information provided by the sample statistics.

Kenneth Stephens
ASQ Fellow
ASQ Quality Press Author

Related Resources:

Browse the free, open access articles below, or find more in the ASQ Knowledge Center.

Acceptance Sampling With Rectification When Inspection Errors Are Present, Journal of Quality Technology

In this paper the authors consider the problem of estimating the number of nonconformances remaining in outgoing lots after acceptance sampling with rectification when inspection errors can occur. Read more.

Zero Defect Sampling, World Conference on Quality and Improvement

Zero defect sampling is an alternative method to the obsolete Mil Std 105E sampling scheme previously used to accept or reject products, and the remaining ANSI Z1.4-1993 which is still in use. This paper discusses the development of zero defect sampling and compares it to Mil Std 105E. Read more.

Explore the ASQ Knowledge Center for more case studies, articles, benchmarking reports, and more.

Browse ASQ magazines and journals here.