Anyone who has been involved in the quality assurance and food safety side of the food business for any length of time knows that one of the top items on the list of those that will keep you awake at night is whether or not your product “hold” or retention program will be effective in preventing the shipment of product when needed. Product can be held for a number of reasons and many of the reasons can be the trigger for a recall if for some reason the product is shipped. I had it happen to me at several different companies for several different reasons. Unless the product is physically “locked up” and you have the only key, you need to ensure you have as many hurdles as possible in place to: (1) account for all product on hold, and (2) make it as difficult as possible to “accidently” ship the product.
It is also important that the correct product is on hold – but that topic will be discussed in a separate blog.
Reasons Why Product May Be Held
Companies have hold or retention programs to retain products for a number of reasons. Product may be retained – usually by the QA department – for quality reasons that don’t affect the safety of the product, but don’t meet the customers’ or your specifications. If this product is “accidently” shipped, you may have unhappy customers or consumers but there is no food safety risk and the product does not violate any regulatory requirement. However, your customer’s brand or your brand could suffer if this happens too many times.
Products held for regulatory violations or food safety reasons are the ones which will get you in trouble if your hold program is treated as an afterthought – especially when the warehouse or distribution center is looking at filling orders. Product might be held because its labeling is wrong; for example, it doesn’t declare an allergen. Other reasons include that you or a government agency tested the product or a food contact surface for a pathogen such as Listeria monocytogenes or Salmonella. In fact, when FSIS takes a sample, it is a regulatory requirement that you hold the product until the results are obtained.
If you are a FSIS-inspected establishment, you might also have product on hold because the FSIS inspector has placed a retain tag on the product. In these situations – whether or not the product is held for a food safety reason – violation of the FSIS retain tag brings on another whole set of problems for you of which a recall maybe the smallest!
What Makes a Robust Hold Program?
Accurate Inventory
A robust hold program needs a number of hurdles to allow you to sleep at night when there is product you absolutely do not want to leave your control. Regardless of whether the hold is for quality or food safety reasons, all should begin with an accurate inventory of the amount of product being placed “on hold.” If this is a hold to control product that a FSIS inspector has also tagged, make sure the product is inventoried with the inspector and you both agree on the amount.
It is important to have a written document or computer-generated form where the product details are recorded. This should include the product name, product code, date of hold, reason for the hold, the person placing the product on hold, and quantity. When product is released, the disposition and the number of cases released should be recorded. If cases are pulled from the hold for testing or any other reason, these also need to be noted.
Contain the Product
Many times the effectiveness of the hold can be determined by the amount of product you need to hold. For example, if you have several cases of product or maybe even several pallets, you may have a retain cage where these can be placed under lock and key – with you holding the key. But there are few areas that are large enough to hold a day’s production or more under a physical lock and key. One way to hold the a large amount of product is to load it on a refrigerated trailer, lock the door, chain the trailer to an unmovable object, and keep all keys! I know at least one General Manager who did this to ensure she could sleep at night and know that no product would “accidently” disappear. However, there have been a few isolated cases where entire trucks have been stolen so this should also be a consideration!
If the product is being held for food safety reasons and the product cannot be held under lock and key, have it inventoried daily to ensure it is all there. Document this check. Many companies with computerized inventory systems have the ability to “lock-out” any hold product from being visible by the warehouse personnel that are filling orders. This is one good hurdle, but it is important that the product actually be “locked out” in the system or it might still get shipped. Keep in mind that the product is still physically visible, so make sure you also have visible hold tags on it.
Companies should also ensure that the physical product has hold cards visible to fork truck drivers. Use large, bright tags, and also bright hold tape such as that used for crime scenes, to tape off the racks. And if the hold tag is not on the side of the pallet that the driver can see, it does no good; place visible tags on each side of the pallet to prevent the excuse that “didn’t see the tag.” And again, inventory the product daily to be sure none of it has walked away.
If you are holding product at a public warehouse, you must work with the warehouse to ensure it has a robust hold program. Make sure that your personnel controlling the product at that location understand the need to ensure the program works. It is always preferable to keep the hold product at your location where you have control.
Follow the Program
Companies should also make sure that any product on hold is properly released with the hold tags removed and disposition documented. If no one in the QA department takes the time to remove the tags and you allow just anyone to do so, you have just diluted the effectiveness of your program. If no one documents disposition and release of product, you have also diluted the effectiveness of your program.
You should also mandate that the product hold inventory is reconciled regularly. Hold people accountable for violations of the program. Of course, this can only be done after you provide appropriate training on the program to everyone. Hold tags, both QA and FSIS, must be respected if you have any chance of ensuring that when product must absolutely remain under your control; that it will. Remember that Murphy’s Law is always working against you and if product is easy to ship when on hold, it will happen!
About “Ms. Gloom”
In the attorney ranks at OFW Law, there is only one who would raise a hand if all were asked if they had any “hands-on” experience in the operation of a Townsend “Frank-O-Matic” hotdog maker, producing bean sprouts for use in egg rolls or in managing a food facility sanitation crew. In fact, there are probably no attorneys out there who could raise their hands except Jolyda Swaim.
Prior to law school and OFW Law, Ms. Swaim spent years in the food industry, beginning as a microbiologist and Quality Assurance technician. In these years, she had direct charge of quality assurance, production, sanitation and consumer affair departments at various companies producing products from pickles, sauerkraut and barbeque sauce, to various meat and poultry products, to frozen entrees, egg rolls and pizza to spices and spice blends. Her last position at Sara Lee as Director of Food Safety had her auditing its facilities in the United States and Mexico to ensure facilities producing ready-to-eat products were following best practices in sanitation and product handling.
