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M&S THE CONTROL AND VERIFICATION OF PACKAGING, LABELLING AND CODING OF MARKS AND SPENCER PRODUCTS October 2015 v5
M&S Section 1 – Mandatory Decision Tree
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ESSENTIAL REQUIREMENT: All suppliers must complete the decision tree in this section to determine the method of packaging verification and date control required. The decision tree must be completed on a packing line-by-packing line basis and must take into account every M&S finished product packed at the site, including seasonal lines. The decision tree must be agreed with, and formally signed-off by, the relevant Marks and Spencer Food Technologist.
M&S 1.1 General Requirements
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1.1.1 The decision tree must be completed for each separate packing line in order to decide if manual or automated controls are required.
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1.1.2 Each decision tree must be reviewed, and resubmitted to M&S for approval, when new products, new packaging or any other relevant changes are introduced.
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1.1.3 M&S Connect must be updated whenever the decision tree outcome(s) is changed to ensure the status of the factory (in relation to manual or automated controls) is accurate.
M&S Section 2 – Mandatory Requirements for all Suppliers ESSENTIAL REQUIREMENT: Where the need for a manual system has been identified through the decision tree assessment, suppliers must operate a method of verifying packaging, labels and date codes which is in full compliance with the requirements of this section.
M&S 2.1 Principles
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2.1.1 The system used to verify the packaging, labelling and coding of M&S products must apply to all finished packaged retail food products and be flexible to accommodate a wide range of production line, packaging and label formats.
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2.1.2 Where different, but visually identical or similar, products are being packed e.g. whole milk and skimmed milk, potato topped pies etc., adequate production controls must be in place to ensure the correct product is being packed. For example, adequate spacing between different products in continuous production, breaking open pies and crisp bakes, or using colour-coded foils.
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2.1.3 In the event of using incorrect packaging and/or date code on an M&S finished product, the M&S Technologist must be notified immediately.
M&S 2.2 Printing, Receipt and Storage of Packaging
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2.2.1 Composite printing of food packaging (i.e. where different products or different variants of a product are printed at the same time on one sheet or reel and then split in a separate process) must not be carried out for M&S products unless this has been agreed with the relevant M&S Food and Packaging Technologists.
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2.2.2 If mixed packaging is received from a packaging printer e.g. printing or labels on a film reel, the stock must be isolated immediately and the relevant M&S Technologist informed
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2.2.3 All packaging must be assessed on intake for compliance with agreed specifications to ensure the correct version has been delivered. This must be done by identifying a unique mark on the packaging which denotes version number e.g. the 2D barcode.
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2.2.4 All packaging must be stored within a secure and clearly dedicated area.
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2.2.5 Where packaging such as film, labels, sleeves, promotional stickers, have been decanted from their cardboard outers, adequate signage and/or shelf labelling must be used to clearly indicate the exact storage location for the packaging for each individual UPC.
M&S 2.3 Transfer of Packaging to Production Lines
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2.3.1 A record must be kept of packaging issued to and returned from every production line to prevent more than one set of packaging being issued to a line at any one time. The collection and issuing procedure must be carried out only by trained and authorised staff.
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2.3.2 There must only be one set of packaging present on each production line at any one time and this must be stored in one clearly identifiable location near to its point of use.
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2.3.3 Each item of packaging supplied to every production line must be verified as being the correct item and correct version before packing commences. This includes when a box, batch or reel of labels/stickers runs out and is replaced during a production run.
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2.3.4 At any product changeovers and at the end of production runs, all packaging must be returned to its appropriate storage location prior to the next product and packaging being brought to the line. A visual check of the packing equipment and all relevant parts of the line must be carried out to confirm that all relevant packaging has been removed. This check must be documented and signed-off.
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2.3.5 Any left-over pre-coded packaging must be destroyed. The amount must be recorded and the disposal documented.
M&S 2.4 Date Coding Schedules (only applicable to Manual Date Coding)
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2.4.1 Product date codes must be derived from a documented coding schedule available at the point at which codes are entered into the coding equipment.
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2.4.2 The coding schedule (including pricing where applicable) must be written in exactly the same format as the code is expected to appear on product packs e.g. 24/04/2013 not 24 APR or 24/4/13.
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2.4.3 The times at which coding date changes occur must be defined in the site QMS and this information must be clearly stated on the coding schedule. This must be agreed with the relevant M&S Technologist.
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2.4.4 Where there is a change of month or year on the date code, this must be clearly indicated on the coding schedule.
M&S 2.5 Coding and Labelling Verification
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2.5.1 For every production run, a full visual check of all relevant aspects of finished product packaging (including date code, product name, UPC etc.) must be carried out on:-<br>- the first pack produced in the run<br>- the last pack produced in the run<br>- the first pack produced after any break in production (i.e. box or carton change, film reel changes, staff breaks and fire alarms) and - every 30 minutes during the production run.<br>Where a product has multiple labels, the verification must ensure that each label is present and correct.
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2.5.2 The results of these checks must be recorded, signed-off and the complete packaging must be retained until at least the end of the product’s shelf life. Where the samples cannot be physically attached to the coding sheet, they must be stored in a suitable location with the date and time of the check recorded on them. <br>Where a site cannot retain all of the packaging from the checks done during a run, it is acceptable to take photographic records of these checks rather than retaining the packaging; however, all relevant aspects of the finished product packaging must be captured and the site must be able to demonstrate that the information has been verified as accurate and correct. In addition, these records must be easily retrievable for the purpose of audit, investigations etc.
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2.5.3 Reference samples, or photographic standards, of the packaging being used for each production run must be available to those staff carrying out the checks. The samples must include key distinguishing information with points of difference clearly highlighted.
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2.5.4 All line checks must be carried out by the person responsible for running the packing line.
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2.5.5 Date codes must be checked against the coding schedule and written down exactly as they appear on the packaging.
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2.5.6 The correct location and legibility of the date code must be checked either by use of a suitable vision system or this can be carried out manually and recorded.
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2.5.7 Where packaging is coded off-line, checks to confirm the correct coding has been applied must be carried out at the point of printing in addition to on-line verification checks. Only one set of packaging from one product must be worked on at any one time and the working area where this activity is carried out must be completely cleared of all other packaging.
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2.5.8 Where, in some cases, finished packed products are not coded at the time of packing, there must be suitable documented procedures in place to ensure full control of these products. In these instances, each product must be labelled with a batch code or Julian code for ease of traceability and stock control. Where possible, the in-line system of coding must be extended to include this facility.
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2.5.9 Date-code printers must be maintained and serviced in accordance with the manufacturer’s instructions to avoid poor quality printing and/or downtime.
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2.5.10 Where products are coded off-site from the manufacturing and packing site, the external coding company must have suitable facilities, standards and controls in place to ensure that different packaging cannot become mixed during the process. In these cases, a risk assessment must be carried out to determine the relevant controls and checks required. This must be agreed with the relevant M&S Technologist and recorded.
M&S 2.6 Promotional and Other Non-routine Product Labels and Stickers
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2.6.1 Any promotional labelling must be included on the coding schedule with a clear indication of the start and end dates for the use of the labelling. An effective internal system must be in place which ensures that all information on the coding schedule is jointly agreed, verified and signed off by the Technical, Operational and Commercial teams.
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2.6.2 Where practical, this type of labelling must be applied automatically online as the product is running. Irrespective of whether the labels/stickers are applied automatically or manually, it must be ensured that no other information on the pack is obscured.
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2.6.3 Where promotional labels/stickers are applied off-line to finished products which are already packaged, this must be carried out in a suitably controlled area.<br>Where this activity is undertaken, the finished, fully labelled packaging must be checked and recorded at the point where the promotional labels/stickers are applied. This check must take place at the beginning and end of each label/sticker reel and a sample of the finished packaging from each check must be retained.
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2.6.4 Where promotional labels/stickers are applied to packaging before product packing, only one set of packaging from one product must be worked on at any one time. The working area where this activity is carried out must be completely cleared of all other packaging. When the work is completed, the labelled packaging must be stored in a secure container, clearly marked and segregated from non-labelled packaging.<br>The finished, fully labelled packaging must be checked and recorded at the point where the promotional labels/stickers are applied. This must be done at the same frequency as the checks required in Section 2.5.1. A sample of the finished packaging from each check must also be retained.
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2.6.5 Where an external company is used as a sub-contractor for the application of labels/stickers to packaging, each item of packaging must be checked by the sub-contractor prior to despatch to ensure it is the correct item. This must be recorded and a sample of the finished packaging retained.
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2.6.6 A sample of all packaging returned from such external companies must be checked on in-take to ensure that the correct labels/stickers have been applied and the positioning is correct. The results of these checks must be recorded. This packaging must then be sealed, clearly marked and stored in a designated area to ensure its segregation from nonlabelled packaging.
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2.6.7 Where promotional and non-promotional versions of the same finished product are on site at the same time, labelling is required to clearly distinguish between them (including when palletised) and effective documented procedures must be in place to communicate the dispatch requirements for each version.
M&S 2.7 Finished Product Tray End and Outer Case Labels and Barcodes
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2.7.1 Barcode printers must be programmed by a designated person and be protected from unauthorised tampering. Date coding must be programmed using the coding schedule.
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2.7.2 The issuing of barcode labels must be controlled and documented. Barcodes must be checked on a regular basis (i.e. daily) using a suitable hand held scanner to ensure they are correct for the finished product being packed and are readable.
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2.7.3 At the end of a production run, any remaining unused labels must be destroyed immediately or returned to controlled storage if to be re-used.
M&S 2.8 Corrective Actions
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2.8.1 Written procedures relating to coding, labelling and packing must contain suitable corrective actions to be taken in the event of an identified non-conformance.
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2.8.2 If there is any risk that non-conforming product has been dispatched, M&S must be informed immediately using agreed communication routes.
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2.8.3 A documented investigation must be carried out to identify the cause of all issues including situations where none of the product has been issued to the customer. Any corrective action taken as a result of the investigation must be recorded as part of the investigation.
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2.8.4 All relevant staff must be trained on the action to be taken in the event of a non-conformance. Suitably trained staff must be on site at all times when coding, labelling and packing is taking place.
M&S 2.9 Training
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2.9.1 All relevant staff, including those who are involved in the management of manual packaging verification/date coding systems and those who complete the relevant checks, must be fully trained against the site’s documented procedure and the principles of packaging verification and date code control. Training records must be in place and available for inspection.
M&S Section 3 - Automated on-line Packaging, Labelling and Coding Verification Systems
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ESSENTIAL REQUIREMENT: Where the decision tree identifies the need for an automated system on one or more production lines, suppliers must install a fully automated packaging verification system and/or date coding control system that covers all M&S products on those lines and which complies in full with the requirements of this section. This is in addition to the requirements of Section 2.<br>Where a site has an automated system installed, a documented Gap Analysis must be available for audit to demonstrate compliance with the each requirement of this section. The Gap Analysis must be signed and dated by both the equipment installer and a site senior manager.<br>Where an automated system is needed, full verification controls (see Section 2.5.1) must be in place during the installation period (i.e. manual and automated controls run in parallel). Once the site is satisfied the system is functioning correctly and can demonstrate all relevant staff are suitably trained and competent, the site can remove the full verification controls and replace with checks of:-<br>1) the first pack from every run; and<br>2) the first pack produced after any break in production (i.e. breakdowns, staff breaks and fire alarms).<br>If the automated system is partially or completely disabled, sites must have a system in place to immediately implement manual verification systems in order to cover the function(s) that has been disabled. In such instances, sites must immediately notify their M&S Lead Technologist and put manual verification systems in place. In addition to this, a member of the management team (i.e. QA manager, Technical manager or their trained, nominated deputy) must verify the correct date and version of packaging as the first and last packs from each production run are produced. This must continue until the automated system is fully functional.
M&S 3.1 AUTOMATED PACKAGING VERIFICATION Every automated system that has been installed must comply with the following equipment specification and operating procedures:
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3.1.1 Information Downloading and Back-up<br> To automatically download all relevant product specific information from a centrally-controlled database to the required production lines and all associated on-line label verification equipment.<br> Each production line that has an automated system installed must be controlled by a line terminal. It is possible for 1 line terminal to control the automated systems on more than 1 production line, therefore, sites must install an appropriate number of line terminals to operate their systems.<br> Line terminals (or other suitable hardware) must be suitably located to enable them to continue to operate the on-line automated system in the event of a failure of the centrally controlled database, planning system or network. All locally generated line data must be automatically uploaded to the central database to ensure an unbroken auditable record of events<br> The centrally controlled database must be stored on suitable equipment in a secure location e.g. a server. Sufficient back-up regimes must be in place so that, in the event of software or hardware failure on this equipment, data loss is minimised.
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3.1.2 System Access<br> Access to the central database for data input or editing must only be available to appropriately authorised and trained staff i.e. via password or swipe card access.<br> Any changes made must be approved by a more senior member of the management team who is suitably trained and using a separate level of system access rights. Where changes occur, an automatic audit entry must be made to indicate the originator, approver, date of change and the change in the product details.<br> Access to the automated system on the product packing line must be controlled i.e. by using a system of unique passwords or swipe cards. These must only be available to appropriately authorised and trained staff and must only be used by the person who was given the password/card.
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3.1.3 Automated Pack Label Verification<br> The automated system must provide continuous monitoring of each finished product pack by on-line scanning of packaging bar codes or other unique identification code or mark (i.e. 2D barcode) to verify that every packaging component used is correct for the product being packed. This unique code or mark must also be associated with the individual packaging artwork in order to verify that the correct version of packaging is being used. For starting each new product run, operatives must select the product on the line terminal rather than scanning the packaging because if the packaging is the wrong type/version, the system would not recognise the error.<br> For every production run, a full visual check of all relevant aspects of finished product packaging (including product name, UPC, unique code etc.) must be carried out on:- - the first pack produced in the run; and - the first pack produced after any break in production (i.e. breakdowns, staff breaks and fire alarms) Where a product has multiple labels, the verification must ensure that each label is present and correct.<br> The automated system must, wherever practical, be extended to include additional labels/stickers applied to packaging e.g. for promotions, where additional sensors, scanners or vision systems can be used.<br> The automated system must, wherever practical, be extended to accommodate multipacks e.g. where variety multipacks are produced,scanners and/or colour sensors can be used to verify that the correct number of each variety have been packed.<br> The system must be set up to limit the maximum number of consecutive ‘no reads’ e.g. no more than 3. Where this limit is exceeded, the line must be designed to immediately stop and audibly and/or visually alarm.<br> In the event of the automated system detecting a major fault e.g. incorrect label being used, then the system must be set up to automatically stop the product packing line. In such instances, the cause of the fault/error must be investigated immediately and corrective actions taken before restarting the line. It must only be possible to re-start the line with approval from appropriately authorised and trained staff i.e. using password or swipe card access.<br> Audible and/or visual alarms must be installed and functioning to warn of any detected faults.<br> Provision of a historical record of all events (i.e. an integrated audit log) including any technical adjustments and line faults, giving sufficient information to allow full audit traceability to demonstrate technical compliance.<br> In the event of the automated packaging verification system being partially or completely disabled, there must be a documented procedure to immediately implement manual systems in order to cover the function(s) that has been disabled. In such instances, sites must immediately notify their M&S Lead Technologist and put manual verification systems in place. In addition to this, a member of the management team (i.e. QA manager, Technical manager or their trained, nominated deputy) must verify the correct version of packaging as the first and last packs from each production run are produced. This must continue until the automated system is fully functional.
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3.1.4 Testing of Automated Packaging Verification Equipment<br> Checks must be carried out at the beginning of each shift to ensure that the failsafe mechanisms are functioning correctly. This can be carried out by presenting incorrect packaging to the line and observing that the line stops and alarms. The result of this check must be recorded.<br> Checks must be carried at the start of each day (i.e. at the beginning of the first shift) to ensure that all sensors associated with the automated system are functioning correctly. This can be carried out by covering each sensor for a short time (i.e. 5 seconds) and observing that the line stops and alarms. The result of this check must be recorded.
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3.1.5 Purchase of New Product Packing Equipment<br> Where a site’s food product packing equipment, which is used for M&S product, is being changed e.g. replacing or adding equipment such as flow wrappers or labellers, the provision of an automated packaging verification system as outlined in this Code of Practice must, where relevant, be included within the equipment specification.
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3.1.6 Security of Historical Data<br> Regular back-ups must be taken off-site and archived in a secure location.
M&S 3.2 AUTOMATIC DATE CODE CONTROLS Every automated date code control system that has been installed must comply with the following equipment specification and operating procedures:
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3.2.1 System Access<br> Access to the automated date code central database for data input or editing must only be available to appropriately authorised and trained staff via password or swipe card access.<br> Any changes made must be approved by a more senior member of the management team who is suitably trained and using a separate level of system access rights. Where changes occur, an automatic audit entry should be made to indicate the originator, approver, date of change and the change in the product details.<br> Access to the automated system on the product packing line must be controlled i.e. by using a system of unique passwords or swipe cards. These must only be available to appropriately authorised and trained staff and must only be used by the person who was given the password/card.
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3.2.2 Automated Date Code Control Checks<br> For every production run, a full visual check of all relevant aspects of finished product packaging (including product name/UPC, date code etc.) must be carried out on:-<br>- the first pack produced in the run; and<br>- the first pack produced after any break in production (i.e. breakdowns, staff breaks and fire alarms) This must be cross-checked against the Coding Schedule to verify that the date code is correct as well as present and legible.
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3.2.3 Automated Date Coding and Process Concessions<br> The automated date coding system must provide continuous control of date coding via the network connection to ensure that the date code printed is always correct. Despite the presence of automated date code controls, manual date code verification will still be required as set out in Section 2.5 (i.e. to confirm position and legibility) unless a reduced number of checks has been agreed with the M&S Technologist.<br> Where product information such as ingredients and presence of allergens are printed directly onto the packaging on the packing line, this information must be treated in the same way as the date code to ensure that only the correct information is printed for the product being packed.<br> Coders used for date coding must have their ‘fault state condition’ linked to the packing line. In the event of a coder going into ‘fault’ state, the system must be set up to automatically stop the product packing line for investigation and corrective action to take place.<br> Concessions may be required to allow for deviation from normal product date coding or to allow production to continue in the event of equipment failure. The automated system must, therefore, incorporate sufficient concession management capability.<br> There must be varying levels of management control to ensure any concessions made are approved by a more senior member of the management team who is appropriately authorised and trained. This will require a separate level of system access rights from that of the user requesting the concession.<br> In the event of a concession being requested, only the relevant part of the automated system must be overridden. It must not be possible to disable the entire system.<br> The system must automatically log the originator, approver and the reason for the concession.<br> In the event of the automated date code control system being partially or completely disabled, there must be a documented procedure to immediately implement manual systems in order to cover the function(s) that has been disabled. In such instances, sites must immediately notify their M&S Lead Technologist and put manual verification systems in place. In addition to this, a member of the management team (i.e. QA manager, Technical manager or their trained, nominated deputy) must verify the correct date as the first and last packs from each production run are produced. This must continue until the automated system is fully functional.
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3.2.4 Specific Date Avoidance<br> Ability to prevent a ‘Use by/Best before’ or other date occurring on certain dates e.g. ‘Use By’ 25th December. In such cases, automated rules must be implemented to move the date to a new date which is still within the product shelf life and which has been agreed with the relevant M&S Technologist.<br> Where a one-off change needs to be made to the normal date coding practice for a particular product, management controls must be in place to ensure the variation is only implemented with approval from appropriately authorised and trained staff i.e. using password or swipe card access to the automated system.
M&S 3.3 Finished Product Tray End and Outer Case Labels and Barcodes (Applicable to both automatic packaging verification and date coding controls)
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3.3.1 The extension of the automated system to the control of tray end and outer case labels and barcodes must be considered. This includes the automatic set-up of the tray end or outer case label printer with the correct data and information for the label in a similar manner to the date coding equipment.
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3.3.2 These labels or printed codes should be confirmed scanned by a barcode scanner to ensure they are legible and are correct for the finished product being packed. Any detected major faults e.g. incorrect label or code being printed or ‘no-reads’, must invoke a line stop, alarm and appropriate investigation and corrective action.
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3.3.3 Where the automated system does not currently extend to finished product tray end labels and barcodes, robust manual checks must be in place (refer to section 2.7).
M&S 3.4 Training (Applicable to both automatic packaging verification and date coding controls)
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3.4.1 All staff involved in the management and set up of automated packaging verification and/or date coding systems must be fully trained and certificated by the manufacturer of the equipment or their appointed agent.
M&S 3.5 Servicing of Equipment (Applicable to both automatic packaging verification and date coding controls)
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3.5.1 Automated packaging verification and date coding systems must be serviced on an annual basis.
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3.5.2 Any service work relating to breakdown or failure of the automated system (i.e. not including motors, conveyors, sensors etc.) must be undertaken by the equipment manufacturer or their appointed agent/representative and any spare parts fitted must, where available, be original parts and fully supported by the manufacturer’s warranty.
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3.5.3 A complete system test, including all failsafes, must be carried out following any repairs, maintenance or adjustments.
M&S 3.6 Documentation (Applicable to both automatic packaging verification and date coding controls)
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3.6.1 Written procedures relating to packing, labelling and coding must contain suitable corrective actions to be taken in the event of a breakdown of automated systems. All relevant staff must be trained in against these procedures and records of the training must be available for inspection.
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M&S THE CONTROL AND VERIFICATION OF PACKAGING, LABELLING AND CODING OF MARKS AND SPENCER PRODUCTS October 2015 v5
M&S Section 1 – Mandatory Decision Tree
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ESSENTIAL REQUIREMENT: All suppliers must complete the decision<br>tree in this section to determine the method of packaging verification and<br>date control required. The decision tree must be completed on a packing<br>line-by-packing line basis and must take into account every M&S finished<br>product packed at the site, including seasonal lines. The decision tree must be agreed with, and formally signed-off by, the relevant Marks and<br>Spencer Food Technologist.
M&S 1.1 General Requirements
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1.1.1 The decision tree must be completed for each separate packing line in<br>order to decide if manual or automated controls are required.
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1.1.2 Each decision tree must be reviewed, and resubmitted to M&S for<br>approval, when new products, new packaging or any other relevant<br>changes are introduced.
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1.1.3 M&S Connect must be updated whenever the decision tree outcome(s)<br>is changed to ensure the status of the factory (in relation to manual or<br>automated controls) is accurate.
M&S Section 2 – Mandatory Requirements for all Suppliers ESSENTIAL REQUIREMENT: Where the need for a manual system has been identified through the decision tree assessment, suppliers must operate a method of verifying packaging, labels and date codes which is in full compliance with the requirements of this section.
M&S 2.1 Principles
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2.1.1 The system used to verify the packaging, labelling and coding of M&S<br>products must apply to all finished packaged retail food products and be<br>flexible to accommodate a wide range of production line, packaging and<br>label formats.
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2.1.2 Where different, but visually identical or similar, products are being<br>packed e.g. whole milk and skimmed milk, potato topped pies etc.,<br>adequate production controls must be in place to ensure the correct<br>product is being packed. For example, adequate spacing between<br>different products in continuous production, breaking open pies and crisp<br>bakes, or using colour-coded foils.
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2.1.3 In the event of using incorrect packaging and/or date code on an M&S<br>finished product, the M&S Technologist must be notified immediately.
M&S 2.2 Printing, Receipt and Storage of Packaging
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2.2.1 Composite printing of food packaging (i.e. where different products or<br>different variants of a product are printed at the same time on one sheet<br>or reel and then split in a separate process) must not be carried out for<br>M&S products unless this has been agreed with the relevant M&S Food<br>and Packaging Technologists.
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2.2.2 If mixed packaging is received from a packaging printer e.g. printing or<br>labels on a film reel, the stock must be isolated immediately and the<br>relevant M&S Technologist informed.
