FDA Regulation for Food and Beverage Labels

Inspection, FDA, Packaging, Requirements

Question
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?

Answer
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.

Sampling Plan for Pharmaceuticals

Pharmaceutical sampling

Q: We are a U.S. dietary supplements manufacturer operating under c-GMP conditions set by the U.S. Food & Drug Administration (FDA).

As such, we perform analyses of incoming raw materials (finished product ingredients), intermediate products (during manufacturing), and finished products. Analyses include identity testing (incoming raw materials), and other types of analysis (e.g. microbiological, heavy metals, some quantitative assays on specific compounds). These tests would be the attributes we wish to assess.

Basically, we are refining our sampling procedures and need to ascertain an acceptable number of samples to be taken for the various testing purposes outlined above.

The World Health Organization’s (WHO) Technical Report Series No. 929,  Annex 4, “WHO Guidelines for sampling of pharmaceutical products and related materials” references ANSI/ISO/ASQ 2859-1:1999 Sampling procedures for inspection of attributes – Part 1: Sampling schemes indexed by acceptance quality limit (AQL) for lot-by-lot inspection in reference to the selection of a statistically-valid number of samples for testing purposes.

I note from your website that there are a number of other sampling standards available. I am seeking some guidance as to the most appropriate standard(s) for our particular purposes.

Any assistance you can offer would be much appreciated.

A: Though many of the sampling plans are similar, many standards organizations have published different interpretations of sampling schemes.  Since WHO recommends using ISO 2859-1 as the guidance document, I suggest selecting that plan.

There are similar documents that could be used as an alternative, if necessary:

1. ANSI/ASQ Z1.4-2008: Sampling Procedures and tables for inspection by attributes

2. BS 6001-1:1999/ISO 2859-1:1999+A1:2011 Sampling procedures for inspection by attributes. Sampling schemes indexed by acceptance quality limit (AQL) for lot-by-lot inspection

3. MIL-STD-105E – Sampling Procedures and Tables for Inspection by Attributes*

4. JIS Z9015-0-1999 Sampling procedures for inspection by attributes — Part 0 Introduction to the JIS Z 9015 attribute sampling system

A few points to consider:

  • Usually for FDA-regulated products, a c=0 sampling plan is appropriate. See H1331 Zero Acceptance Number Sampling Plans, Fifth Edition, by Nicholas L. Squeglia
  • Based on risk, an Acceptable Quality Level (AQL) should be selected
  • Your sample size is usually set to be proportional to lot size.  If you are doing testing on bulk raw materials, the sample size will be set based on the variability of the lot as well as the variability of the method.

Steven Walfish
Secretary, U.S. TAG to ISO/TC 69
ASQ CQE
Principal Statistician, BD
http://statisticaloutsourcingservices.com/

Note:

 *military standard, cancelled and superceded by MIL-STD-1916, “DoD Preferred Methods for Acceptance of Product”, or ANSI/ASQ Z1.4:2008, according to Notice of Cancellation

More open access resources about sampling from ASQ:

Explore more in the ASQ Knowledge Center.