By Adem Kulauzovic, Director of Coding Automation, Domino Printing Sciences.
Worldwide, operator error is one of the top causes of labelling mistakes, necessitating costly product recalls which can have a devastating effect on a company’s brand reputation.
On average, a manual production worker can be expected to make one mistake for every 300 touches. However, the reality is, that despite recent advances in automation and production, many companies continue to rely on manual processes to ensure the right information is printed on the right products, boxes, and pallets.
As legislation surrounding the labelling of consumer products becomes stricter in a bid to protect consumers, ensuring efficiency and accuracy in your product labelling operations has never been more essential.
The good news is that, in the Industry 4.0 era, errors arising from manual processes are not only avoidable, but they can also be eradicated quickly and cost-effectively without necessitating significant changes to existing production processes. This article explores the use of automated coding and marking solutions to reduce the risk of costly product recalls.
Where do the errors come from?
In coding and marking, manual processes in both label selection, and label management can ultimately lead to labelling mistakes on a final product:
- Human error in label selection – selecting the wrong label or deploying the wrong information onto product packaging
- Human error in label management – entering the wrong information into a label template to be printed onto a product
The effect of errors
Utilising manual processes can leave production lines susceptible to simple errors, which can pose a tremendous risk to manufacturing operations. Errors in product labelling can necessitate product recalls, which are not only costly in terms of logistics but also have the potential to harm the long-term value of a company.
Consumer protection laws require manufacturers and suppliers to bear the costs of all product recalls – according to a study by Deloitte, food and beverage manufacturers can expect to lose up to USD$10million in wasted stock, logistics, and penalties resulting from a product recall.[i]
It doesn’t stop there – product recalls can also do long-term damage to brand reputation and relationships with consumers.
A solid brand reputation built up over time by providing quality products can be easily undermined by a recall. According to Deloitte, a publicly-traded company can expect to see its stock price decline by up to 22% in the first two weeks after a recall is announced[ii].
In the food and beverage industry, product labelling is of particular importance in ensuring the safety of the end consumer.
In the United States, packaged food and beverage products are consumed by approximately 250 million people each day – when mislabelling occurs, it can pose a significant risk to consumers, as even a slight change in an ingredients list could lead to a product having undeclared allergens.
Product labelling requirements, and standards for recalls, are set by the relevant government regulations in which a food or beverage product is sold.
In the United States, this falls under the Food Allergen Labelling and Consumer Protection Act of 2004 – which applies to the labelling of foods regulated by US Food and Drug Administration. In the EU this is dictated by the Food Information for Consumers Regulation (EU FIC): Regulation (EU) NO 1169/2011. In the UK, the EU FIC is enforced by The Food Information Regulations 2014.
Elsewhere, more governments are beginning to roll out legislation to protect consumers.
The Food Safety and Standards Authority of India recently launched a draft notification for the new Labelling and Display regulations for prepacked food and beverages. The new regulations will make it mandatory for prepacked food to be labelled with information including full ingredients lists, allergens, and related logos for declaration of vegetarian and non-vegetarian items.
In China, allergen labelling on pre-packaged food is currently voluntary, however, in January 2020, the Chinese National Health Commission released a draft bill, GB7718 General Rules for the Labelling for Pre-Packaged Foods, which, if passed, will make allergen labelling compulsory for all pre-packaged foods.
Failure to adhere to regulations surrounding the labelling of food and beverage product can have significant repercussions for manufacturers. In both the EU and the US, errors in product labelling related to allergens necessitate a mandatory recall of all mislabelled products – and despite the consequences, this continues to be an issue for manufacturers the world over.
In November 2019, Stericycle’s US recall index reported that undeclared allergens on food and beverage packaging were responsible for 35.5% of all mandated U.S. Food and Drug Administration (FDA) food recalls for the third quarter of 2019. This represented the highest overall cause of recall for the ninth consecutive quarter.[iii]
The issue is not unique to the US. In the first quarter of 2020, the Food Standards Agency in the UK issues 25 recalls due to undeclared allergies including milk, eggs, nuts, and celery from many big named brands.[iv] Equally, in Finland, data compiled by the Finnish Food Authority (Ruokavirasto) for 2019 found that undeclared allergens accounted for 27% of all product recalls.
Of course, labelling issues are not just an issue in food and beverages: manufacturers of pharmaceuticals and medical devices are also subject to strict legislation surrounding the labelling of products on the market in order to keep consumers safe. Indeed, 9% of all medical device recall events in 2018 – to the tune of over a million units – were due to labelling issues.
Labelling compliance obligations
Legislation and best practice recommendations surrounding the labelling of consumer products have become stricter in more recent years, placing increasing pressure on businesses not just to ensure that labels adhere to safety regulations, but also to put in place systems to identify and solve possible product labelling mistakes before they occur.
Since January 2011, businesses in the US have been required by law to implement preventative measures to avoid labelling mistakes in food and beverage manufacturing. The Food Safety Modernization Act (FSMA), requires manufacturers to implement and monitor effective measures to prevent risks in production, including errors in product labelling.
Globally, the International Food Standards and the Global Food Safety Initiative require that manufacturers and retailers implement procedures for label checking to ensure that products are labelled correctly and within the necessary scope of the laws in which they are sold.
Meanwhile, in the UK, retailers wishing to be a part of the British Retail Consortium must demonstrate that they have a system of checks in place to ensure check and ensure against product labelling errors. This includes having documented processes in place following product changeover, and changes in batches of packaging, to ensure that labels applied are correct for products packaged.
How do you stop the errors?
Having identified that the primary cause of labelling errors lies in manual data entry, the first step towards reducing such errors clearly comes from simplifying or reducing the need for manual data entry on production lines. The answer lies in switching to an integrated system to ensure alignment of your product labelling with your current production order.
At the most basic level, companies can utilise a label design software to automatically populate product labels and manage their distribution across multiple printers from a central location, such as a production office. This reduces the number of data entry points on the line itself, thereby reducing the chance of errors occurring. Furthermore, by replacing individual messages with a template tied to a product database, potentially one can reduce the number of labels being managed from hundreds to only a handful.
Introducing label templates, and so reducing the number of labels required to on production lines, not only makes it easier for manual workers involved in code selection, but it also makes it significantly easier to make changes to labels when legislation changes.
To take a recent example, a Domino customer involved in manufacturing pre-packaged food and beverages needed to make changes to their existing labels due to a change in barcode mandate. The company had over 1,500 labels and making the changes to every single label would have taken an entire week to complete. However, integrating their existing database, which already contained all the required label information, into label templates, allowed them to reduce their label count from 1500 down to just 5, reducing the time spent implementing updates to a fraction of the original.
The next step in error reduction is in establishing good label management. With the simple application of IoT methodology, it is possible to integrate automated coding solutions to automatically populate labels information obtained from a production management system – this can further help to prevent mislabelled products arising from issues in label creation.
Integrated label management solutions can be anything from a simple barcode scanner used to select data from a UPC or production order, to full integration with an existing MES or ERP system – enabling label creation directly from a centralised management system.
Populated labels can then be automatically pushed through to a printer without any manual intervention, mitigating the risk of labelling errors and helping to grow efficiency on production lines.
Validation and vision control
The final step towards error-free coding is in establishing a validation system to ensure that all information on product labels is present, correct, and readable.
Today, high-speed manufacturing environments have made manual inspection of every product impossible and unreliable – an integrated vision control system (VCS) can instead be used to validate a product label, and further reduce the risk of the product reaching a retailer with improper information.
Integrated cameras and a VCS can work alongside coding automation to verify information against production orders and shift codes, to eliminate labelling mistakes. They also can be used to provide verification for item-level serialisation – enabling track and trace of every pallet produced down to the case, or even the product itself.
By checking label quality, a VCS can also ensure that preventative actions are being taken during manufacturing: for example, it can be integrated with coding automation software to automatically stop production if a certain number of ‘no reads’ (products that fail to be read by the VCS) are reached within a certain period, or if the validated label data is inconsistent to the product the system believes is being produced.
In this way, a VCS is an extremely effective quality control tool, which provides an almost immediate return on investment by ensuring that labelling mistakes and quality issues are eliminated before they cause a problem.
Product labelling is of primary importance to manufacturers and brands; yet, making significant changes to production processes is not always feasible. Integrated coding automation solutions can ensure the accuracy of product labelling, without necessitating significant changes to the production lines.
[i] Deloitte, “The food value chain: A challenge for the next century”, accessed 11th May 2020. https://www2.deloitte.com/content/dam/Deloitte/ie/Documents/ConsumerBusiness/2015-Deloitte-Ireland-Food_Value_Chain.pdf
[ii] Mettler Toledo CI-Vision, “Vision Inspection Supports Food Safety Risks of Misinforming Product Content”, accessed 11th May 2020. https://www.packagingstrategies.com/ext/resources/FDP/Home/Files/PDF/FoodWhitePaper_3.23.12.pdf
[iii] Stericycle “Q4 2019 RECALL INDEX”, accessed 11th May 2020. https://www.stericycleexpertsolutions.com/product-recall-index/
[iv] Food Standards Agency, “Alerts”, accessed 11th May 2020. https://www.food.gov.uk/news-alerts/search/alerts?type%5BAllergy%20alert%5D=Allergy%20alert&keywords=&page=0