Rework

Clarify and define exactly what the rework is for each manufacturing facility. Examples may be:-

• For a dry blending plant, a salt based flush material, that is used to clean lines, may be used as rework at a later stage.
• The first flush of a product being sent to a filling line may be collected and used at a later stage or added back, as rework, into the next run.
• An unanticipated stop during production meant that partially prepared product was taken from the line, stored, and used as rework when the line was running again.

Store rework in appropriate, secured containers with any allergens clearly identified. Ensure appropriate inventory controls are in place.

Create standard operating procedures to manage and document the use and control of rework. Consider:-

• Reviewing the use of of rework within HACCP plans, set out how and when the rework can be used, and include records for traceability.
• The form of the rework (for example, powder or liquid) and subsequent appropriate allergen controls.
• The location that the rework will be used (for example, it may be used on a different manufacturing line) and the impact that it has to the facility.
• Strategies to control the use of rework though careful scheduling.

Care needs to be taken when rework is not used during the same production run as this increases the potential for rework with differing allergen profiles being used. Ensure rework is always used in like-for-like products.

Set out rules for when rework cannot be used. For example, finished product that has left your control and contains an allergen should not be reworked if later returned to the facility.

Identify all allergens in the rework, including allergens that are intentionally included as part of a recipe, any allergens that may be present due to cross contact, and the nature of each allergen. Consider using an allergen matrix to clearly set out the information.

Like-for-like allergens that are in different forms may present new risks, for example, rework of a product that contains sesame seeds to be added to a product that contains sesame oil may not be appropriate.

Flush material (such as sugar, salt, or flour used in dry blending plants) can potentially cause cross contact to occur. Flush material should be labelled based on the allergen that it has been exposed to if it is being reused. Flush material needs to be included on the schedule if it is to be used in approved products with the same allergen profile, and this should be done under the direction of technically qualified staff such as Quality Assurance personnel.