29 REWORKING PRODUCT – Food and Drink – Good Manufacturing Practice, 7th Edition

29
REWORKING PRODUCT

Principle

Material may be recovered, reworked or reprocessed by an appropriate and authorised method provided that the material is safe and suitable for such treatment, and traceability of original raw materials and part‐processed product is maintained so that the resulting product complies with the relevant specification and that the related documentation accurately records what has occurred.

General

29.1 Consideration should be given to how reworked material is assessed to ensure that a reworked material is not in itself a potential contaminant. Examples are:

  • material from products containing ingredients or additives such as preservatives and colourants not present in the intended recipient product in which the material will be reworked;
  • material from products being reworked that do not comply with the specific production method (e.g. halal, kosher, organic, vegan, vegetarian) of the intended recipient product;
  • material being reworked not complying with the compositional profile of the intended recipient product (e.g. health products such as diabetic, low carbohydrate or low fat, or products suitable for a low‐calorie diet);
  • material or intended recipient product of a different specified provenance, country of origin, assurance status or designated geographic status so that identity preservation is lost; and
  • material from products containing food allergens being reworked into the intended recipient product where allergens are absent (see Chapter 8).

All reworking activities must be undertaken in line with strict procedures to ensure that the resulting finished product is safe and complies with relevant legal and quality criteria.

29.2 As there are so many different circumstances that can arise with different kinds of food products and processes, it is not possible to be specific here about each of them. The matters referred to here, however, may be classified under three main groups, namely systematic, ‘semi‐systematic’ and ‘occasional’. However, as defined in 29.1, in all circumstances appropriate precautions must be taken to avoid microbiological contamination, introduction of undeclared ingredients, cross‐contamination with allergens or the introduction of foreign matter, and to avoid the loss of traceability and provenance.

29.3 The possible carrying forward of perishable material left over from the previous day should be subject to formal risk assessment by the quality control manager. Where a quantitatively known product residue from the previous production is systematically utilised as one of the starting materials for the same or another product (e.g. dough trimmings in biscuit manufacture), that should be written into the master manufacturing instructions, and the rate or conditions of use there specified should not be departed from other than through the established procedure for varying master manufacturing instructions.

29.4 ‘Semi‐systematic’ applies to instances where a variable quantity of intrinsically satisfactory but extrinsically unacceptable product occurs and can be reused (e.g. misshapen or short‐weight moulded chocolate bars) or to instances where a usable starting material can be extracted from wholesome but defective product (e.g. recovery of sugar as a syrup from misshapen or erroneously formulated sugar confectionery). In such circumstances, provision for such recovery should be made in the master manufacturing instructions, specifying a maximum limit to the rate of incorporation.

29.5 ‘Occasional’ instances are any instances other than referred to in 29.3 or 29.4. They should in all cases be subject to risk assessment by the quality control manager before any decision as to disposition. The four main categories are as follows:

  1. Batches of intermediate or bulk product that have been quarantined as sub‐standard. In some instances (e.g. insufficient salt in a batch of soup or sauce), simple adjustment by addition of the calculated amount of deficient ingredient will suffice; in the case of an excessive amount of an ingredient, rectification may be possible by making a special batch with a calculated deficiency of the ingredient in question and blending the two batches. An alternative in the two cases mentioned, and the only possible use where other types of defect are involved, would be to rework a certain amount of the defective material into a number of succeeding batches. The amount per batch should be determined by experience or a trial where necessary, and agreed by the quality control manager, and should be the subject of a written instruction. Particular regard should be paid to any microbiological or other problems that might arise through holding the material in question for the length of time involved and how traceability can be maintained.
  2. Packed finished product that has been quarantined as substandard. Where the defect is merely soiled, scuffed or badly applied labels, incorrect labelling or stickering, relabelling is appropriate. In instances where the product itself is substandard, it is rare that in‐pack reprocessing would be either possible or appropriate (except in the case of certain canned products where safe heat processing has resulted in products the texture of which could be improved by further heat processing). In general, the utilisation of quarantined substandard packed goods (except in circumstances dealt with in (d) below) requires the emptying of the product from the packages. Its utilisation would then be subject to the considerations indicated in (a).
  3. Packed finished product recalled or otherwise returned from distribution. Similar considerations apply to those referred to in (b), with the addition, however, that as the packs concerned have been outside the control of the manufacturer for a period, they should be assessed even more critically and in the light of information as to their age, history and condition.
  4. In the special case of a group of finished product packages that has failed the reference test for filled weight or volume (either on average quantity or on an excessive number of non‐standard packages), various ways of rectification are possible. In the case of failure only because average quantity is too low and no package is below the legally acceptable minimum, rectification may be effected by blending the group with another group specially prepared with the average as far above the target as the defective group’s average is below it. Where the failure is only through excess non‐standard packages, the group may be rectified by sorting to remove all or most of the non‐standard packages. Another possibility is relabelling with a lower nominal quantity. Finally, if it is feasible to open and reseal containers (where this can be undertaken without compromising food safety), topping up with material from the same batch may be used to increase average quantity or decrease the number of non‐standard packages. The reader is referred to the Code of Practical Guidance for Packers and Importers; Weights and Measures Act 1979 (HMSO) for detailed guidance in this topic.

Rejection

29.6 Inevitably, rejection of materials described above will be necessary from time to time, and proper means of disposal should be considered and agreed with the quality control manager, the production manager and any other interested parties, such as the purchasing manager or sales/marketing departments. In determining disposal, due regard should be paid to the needs of securing cost recovery, protecting the company or brand name, protecting the public and complying with appropriate legislative or local authority requirements. For example, disposal subject to appropriate safeguards might range from sale to a third party for relabelling or packing as a lower‐quality product, to staining and selling for including in animal feed or to seeking local authority condemnation and disposal at their hands. Consideration must be given to compliance with all current European Union (EU) or UK environmental and food and feed safety legislation, including Regulation (EC) No. 1774/2002 (enacted in the UK by the Animal By‐Products Regulations 2003). The EU Animal By‐Product Regulation 1069/2009 and Regulation 142/2011 came into force in the UK and are implemented by the Animal By‐Product Enforcement Regulations 2013 and the Animal By‐Product (Miscellaneous) Amendments Regulations 2015 as specific to each country within the UK.

Relabelling

29.7 In any relabelling of packs, any identifying marks carried by the original labels should be carried by the new labels, and where the pack carries a durability indication on the label, the new label should carry a date no later than the original durability indication.