Next, the production facility should be notified of the complaint details and begin the investigation. It is important that a thorough inspection be conducted because it’s easy for the facility to believe it does not have that source of foreign material in the plant. For example, if the complaint is a piece of metal, the investigation may conclude that the plant was not responsible because of its metal detector. This equipment, however, is not infallible and there are many factors that could allow a contaminated product to not be detected or rejected. As a result, the facility should presume that the food was contaminated by their process. Factors affecting the metal detector can include vibrations from the floor, position near other equipment, or the size, shape, or location of the metal piece in the product. Furthermore, this investigation should begin as soon as the complaint is received, whether or not the object is available. Root cause analysis is critical to determining both where the foreign material entered the process and what caused the system failure that resulted in the contamination.
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An investigation should also consider an unpleasant alternative—tampering. This is particularly important if the complaint is serious, such as a needle or blade in the product, or if the incidents are numerous and sudden. Tampering is unusual, but possible, and it is a criminal activity so consider involving the police early in the investigation.
When the root cause is determined, a corrective action should be implemented and documented. Follow up is necessary to ensure the corrective action is effective and, finally, the consumer should be contacted to close the complaint. Consumers are looking for transparency and honesty; letting them know what went wrong and what corrective actions were taken to prevent the issue from occurring again will build good will with the community.
Using Complaints Effectively
To begin, assemble and analyze your customer complaints and your supplier non-conformance reports using a Pareto chart. A Pareto chart is used to prioritize problems, providing information for the 80/20 rule. In most situations, a few problem categories (20 percent) will present the most opportunity for improvement (80 percent). This valuable quality tool will provide you with data to focus your efforts, both internally and externally.
Despite the best efforts of food safety professionals, foreign materials can enter the food supply at a variety of stages. A comprehensive risk assessment of the raw materials, process, and finished product, as well as a thorough analysis of customer complaints and supplier non-conformances, can assist the facility with identifying and implementing control measures for foreign materials. These preventative measures will reduce the risk of injury and illness to the consumers of their product.
Driscoll is senior project manager for NSF-GFTC. With experience both in the private and public sectors of the food and beverage industry, her background includes quality assurance, auditing, and inspection as well as education in nutrition and public health. Driscoll’s knowledge of regulatory issues and her certification as a HACCP auditor with ASQ add value to NSF-GFTC’s consulting services. Reach her at email@example.com.
References Furnished Upon Request
Need more info on foreign object control? Then check out “Detection Technologies: What Works, What Doesn’t,” also available in the August/September 2013 issue.
By Kathleen A. Martin, PhD