Non-Conformances and the Effect Thereof on Quality of the Product

Now that we have examined traceability through effective recordkeeping, and considerations regarding the management and maintenance of Good Agricultural Practices, it is important to examine the implications of non-conformance and explore possibilities for corrective actions. In the context of food safety management systems, the term “non-conformance” is used not only to describe products that are potentially unsafe because is deviates from set standards but also to describe the processes and procedures that were deviated from in the first place and caused the deviation in the product.

A food safety management system is designed to consistently produce products that adhere to certain quality and safety standards. The system should be such that as long as all prescribed policies and procedures have been adhered to the product is virtually guaranteed to be safe and of good quality.

Assuming that the food safety management system adheres to these requirements, it follows that only non-conformance or non-compliance to the prescribed policies and procedures can result in a product that does not conform to quality and safety standards because it was produced or manufactured during a period when critical limits were violated or exceeded, or when an organisation has lost control of a prerequisite program (PRP) or an operational prerequisite program (OPRP).

The Impact of Non-Conformance

Non-conformance to food safety procedures may compromise product quality by causing blemishing, contamination, accelerated decay, or exceeding of maximum residue levels, which would render it unsafe for human consumption or unsuitable for meeting specifications of export markets. Many exports or local contracts are based on the assurance provided by the implementation of and management according to a food safety management systems and adherence to Good Agricultural Practices. The buyer of fresh produce would not be satisfied with a product that does not conform to the standards and specifications. Additionally, it will raise concerns for the buyer if they find repeated instances of non-conformance to the plan. Regulations of importing countries allow for fruit that does not conform to quality and safety standards to be quarantined and such fruit cannot be sold in that market.

The Role of Traceability and Recordkeeping in Identifying Non-Conformance

The purpose of traceability and associated recordkeeping was discussed previously. As part of the food safety management system, data and records associated with traceability are analysed and interpreted in order to identify instances of non-conformance.

This is done both on an ongoing basis, where the records that relate specifically to identified risk areas, or critical control points, are monitored to ensure that critical limits are maintained. If critical limits are exceeded at any critical control point, the planned corrective action must be taken immediately to eliminate or control the non-conformance. Records related to traceability is also useful in determining the point at which non-conformance occurred if it is found that the end-product does not conform to safety and quality standards. Because traceability records are designed to provide a complete picture of the process to which the fruit was subject, the point at which the critical limits were exceeded can be identified if non-con-forming fruit is found.

Example: Non-Conformance and Recordkeeping In 2006, a consignment of fruit was found on arrival in Japan to exceed maximum residue levels. The consignment consisted of 4,000 pallets of fruit. The procedure in such a case prescribes that the entire consignment is rejected until it can be proven that not all the fruit was subjected to the same processes. Because the grower had sound traceability records, he could prove that most of the fruit was not subject to processes where the critical limits were exceeded. The non-confirming fruit was accurately identified, and the remainder passed inspection.