Non-Conforming Product Control Procedure

Control product when conformity cannot be confirmed

Non-conforming status applies not only when product fails a specified requirement, but also when conformity, release status or acceptability cannot be positively confirmed. The procedure specifically covers loss of control, loss of identification, missing or incomplete records, abnormal events and other circumstances that prevent assurance of compliance, as well as reasons to suspect that product quality or safety may be compromised.

Returned product is treated as non-conforming on receipt from any source and is brought under the same identification, control, segregation and authorised disposition requirements.

This gives the document a defined control position for uncertain product status without requiring a confirmed failure before protective controls are applied.

Maintain clear status, segregation and hold controls

Non-conforming product must be clearly designated so that it cannot be confused with conforming product. Where electronic systems are used, system status controls are applied in addition to physical identification.

Segregation can use physical, system-based or procedural means according to the product, process and operating environment. Where physical segregation or dedicated storage is unavailable, the procedure requires alternative controls that provide an equivalent level of protection against accidental release.

The controls remain in place until an authorised disposition decision is made. Product is held so that movement, use or release is prevented and, where applicable, its condition is maintained.

Place disposition decisions under defined authority

Technical or Quality Management is responsible for defining, documenting and approving disposition decisions. Authorised options may include rework, reprocessing, downgrading, disposal or controlled release where permitted.

Where customer-branded or customer-owned product is involved, or contractual requirements apply, the decision is referred to the customer or brand owner for approval where required and the outcome is documented.

For permitted rework or reprocessing, activities are defined and controlled, the product must meet the applicable specification before further use or release, and the outcome is verified and recorded. Where product is destroyed for food safety, legality or quality reasons, destruction records provide evidence of quantity, method, date and Technical or Quality Management authorisation.

Allocate responsibility from governance to day-to-day control

Senior management provides the resources needed for effective control, segregation and disposition, assigns clear disposition authority and reviews significant issues where escalation is required.

Technical or Quality Management manages the non-conforming product process, confirms that only authorised personnel make disposition decisions, maintains records, verifies that controls are implemented effectively and escalates issues against defined criteria.

Department Managers or Functional Leads are responsible for immediate local identification and control, including segregation, labelling and access arrangements. Employees are required to identify and report suspected or confirmed non-conforming product and comply with the controls applied to it.

Keep evidence and competence aligned with the control process

Records are maintained to demonstrate effective control and include, as applicable, product identification, status designation and location, the authorised disposition decision and the outcome of disposition activities.

Personnel involved in identification, segregation, control, handling, authorisation or disposition must be suitably trained and competent for their assigned roles. Training covers the recognition of non-conforming product, application of status and segregation controls, authorised disposition pathways, controlled disposition activities where applicable and completion of required records.

Connect product control with related FSQMS procedures

The procedure deliberately defines its own boundary. Investigation, impact assessment, root cause analysis, corrective action and preventive action are governed by the Corrective & Preventive Action Procedure; traceability, mass balance and reconciliation by the Traceability Procedure; and incident management, product withdrawal and recall by the Incident Management, Product Withdrawal & Recall Procedure.

That separation keeps non-conforming product control focused on product status, containment and authorised disposition while preserving clear interfaces with the wider FSQMS when other forms of investigation, traceability or incident response are required.