Insight on Importance of Hold and Release Program of Non-Conforming Product Used in Food Industry

Hold and Release program is a preventive measure program which safeguards the company against product recall and provides assurance that non- conformity ingredients/products are not used at any stage of the food supply chain. This program is a great way to ensure that the finished product that your food business is sending out into the marketplace is not only going to be safe, but also meet the desired product attributes. A food product can be classified as safe when it does not contain any biological, chemical, or physical hazards.

Non-conforming product is defined as a product at any stage in the process that does not meet agreed food safety and quality criteria. This can apply to any raw materials, ingredients, packaging materials, work-in-progress or finished product. It can also apply to any other material used in the facility that can impact product safety or quality, e.g. cleaning chemicals, processing aids, equipment.

Elements of Hold and Release Program 

Hold and Release Planning:

Hold and Release plan should include:

  • a written detailed plan that includes plant-specific procedures to be used to implement an effective program. 
  • Include a tracking and documentation system that identifies the product(s) placed on hold, and the release or appropriate disposition process upon receipt of test results.
  • Provide written justification for production issues (e.g., raw materials, product shelf-life, physical space to hold product, ability to fill customer orders, line separation) to support the requested notification time prior to agency sampling.


Marking/ Tagging System:

Markers and Tags helps in distinguishing products held/ rejected from other products. Examples of identification systems include:

  1. Use of color-coded shrink-wrap,
  2. Use of color-coded tape (like crime scene tape), or
  3. Use of color-coded tags

Address the tracking of product held (e.g., where is it located, if transported offsite – carrier, delivery information, location at off-site storage).


Maintaining Control of Product(s) being Held:

Establishments should have following procedures in place to prevent products being held from entering production area:

  1. If possible, store the product being held away from other products.
  2. Clearly identify the product being held to distinguish it from other products to prevent it from being shipped accidentally.
  3. Protect unpackaged product from cross-contamination.
  4. Track the location of the product being held during storage and transportation.


 Test and Hold programs should:

  1. Provide a written, detailed description of the entire test and hold procedure.
  2. Ensure control of the product(s) being held.
  3. Include a written agreement with all off-site storage facilities used to store product while it is being held pending test results.
  4. Document Certificate of Analysis (COAs) and any test results for any raw materials being used in raw, ground product.
  5. Document COAs, any test results and letters of guarantees from suppliers of raw materials.
  6. Provide a documentation system that:
  • Identifies product(s) being held
  • Includes date and time of sample collection
  • Includes product name
  • Includes raw material information
  • Includes production or lot code
  • Includes product volume
  • Includes plant contacts
  • Includes the release of product or appropriate disposition
  • Document sanitation and reinspection procedures designed to ensure the separation of product runs or production lines.

Clearly, food control involves many difficult issues. Some of these are highly technical, while others are partly technological and partly political. The mutual goal should be to resolve these questions in a way that considers the needs of governments, consumers, and industry. For governments, there is the need for enforceable standards that are convincing to both consumers and industry. For consumers, food control systems must provide meaningful protection against real and important hazards. Finally, industry needs standards that permit flexibility and efficiency in producing and marketing foods that will serve their customers – the world’s consumers.




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