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[[File:|right|400px]] Title: How can a LIMS help a food and beverage laboratory better handle incident management and corrective action?

Author for citation: Shawn E. Douglas

License for content: Creative Commons Attribution-ShareAlike 4.0 International

Publication date: February 2024

Incident management and corrective action in general

Numerous regulations, standards, recommendations, and guidelines make clear that incident management and corrective action must be addressed by businesses in multiple industries, not only within their workflows and processes but also within the information systems they use to better manage those workflows and processes. Examples include:

• 9 CFR Part 417 - Hazard Analysis and Critical Control Point (HACCP) Systems61 FR 38806, 9 CFR Part 417.3
• 21 CFR Part 225 - Current Good Manufacturing Practice for Medicated Feeds 21 CFR Part 225.58 (d)21 CFR Part 225.158
• 42 CFR Part 493, Subpart K - Quality System for Nonwaived [Clinical] Testing 42 CFR Part 493.128242 CFR Part 493.1289
• A2LA C211 - Specific Checklist, Combined ISO-IEC 17025-2017 and Veterinary Laboratory Accreditation ProgramA2LA C211 4.8 and 4.11
• ASTM E1578-18 - Standard Guide for Laboratory InformaticsASTM E1578-18 E-9-5
• BRC Global Standard Food SafetyBRC GSFS, Issue 8, 3.4.3BRC GSFS, Issue 8, 5.6.1.2BRC GSFS, Issue 8, 9.3.5
• CDC Biosafety in Microbiological and Biomedical Laboratories (BMBL), 6th EditionCDC Biosafety in Microbiological and Biomedical Laboratories (BMBL), 6th Edition
• E.U. Commission Directive 2003/94/EC of 8 October 2003 laying down the principles and guidelines of good manufacturing practice in respect of medicinal products for human use and investigational medicinal products for human useE.U. Commission Directive 2003/94/EC Article 13
• FDA HACCP Principles & Application GuidelinesFDA Hazard Analysis Critical Control Point Principle 5
• GFSI Benchmarking Requirements, Version 2020GFSI Benchmarking Rqmts., v2020.1, Part 3, A1, A2, B1, B2, B3, C0, C1, C2, C3, C4, D, I, K - FSM 22
• NYSDOH ELAP Medical Marijuana Microbiology GuidanceNYSDOH ELAP Medical Marijuana Microbiology Guidance
• NIST 800-53, Rev. 5 - Security and Privacy Controls for Information Systems and OrganizationsNIST 800-53, Rev. 5, AU-6(1)NIST 800-53, Rev. 5, IR-4(1) and IR-5NIST 800-53, Rev. 5, SI-2 and SI-4
• SQF Institute Food Safety Code, Food Manufacturing, Pet Food Manufacturing, and Manufacture of Food PackagingSQF FSC 9, Food Manufacturing, Part B, 2.5.3SQF FSC 9, Pet Food Manufacturing, Part B, 2.5.3SQF FSC 9, Manufacture of Food Packaging, Part B, 2.5.3
• WHO Technical Report Series, #986, Annex 2 - WHO good manufacturing practices for pharmaceutical products: Main principlesWHO Technical Report Series, #986, Annex 2, 2.1 (f, j)WHO Technical Report Series, #986, Annex 2, 5.0

An incident is typically represented as a deviation from a standard operating procedure or standardized method that leads to a product outcome that is less than ideal, such as a substandard or injurious product before or after distribution, a low-quality or poor-tasting product that causes customer or consumer dissatisfaction, a product demonstrating regulatory non-compliance, or a product with generally perceived food safety issues.

As part of preventing incidents, the food and beverage manufacturer must not only ensure a well-designed and operational food safety system but also that it is able to monitor unsatisfactory or near-miss situations, analyze their trends and consequences, and investigate their root causes to better enable corrective and preventative action.

The areas where the laboratory has the greatest impact in identifying potential and real incidents is through regular and/or randomized testing to ensure HACCP critical limits aren't violated, as well as other varieties of verification testing (e.g., raw material monitoring, environmental monitoring, end-product quality control (QC) testing, or even investigation of employee-reported issues) at various points along the manufacturing process. This is usually done in-house or with a contracted third-party laboratory, but in the case of incident management where testing doubts arise, some other independent accredited laboratory may be needed to perform testing.

Increasingly common in modern laboratories, a laboratory information management system (LIMS) can prove useful in these matters. The next section explains how.

How can a LIMS help?

A modern LIMS for food and beverage laboratories is able to address a wide variety of needs for the lab, from sample reception, testing, tracking, and results management to quality, security, compliance, operations, and report management. Some of that functionality is driven by regulations, standards, recommendations, and guidelines like those outlined in the previous section. In particular, some LIMS vendors have incorporated some basic form of non-conformance and incident management tools, but the robustness and extensibility of that functionality may vary from solution to solution.

The ideal LIMS might help food and beverage businesses directly or indirectly with incident management and corrective action in a number of ways. The LIMS, for example can:

• automatically send an SMS, email, or alert to the appropriate supplier (or in-house business contact) in real-time when a pre-defined set of limit-breaking or non-conforming testing circumstances concerning that supplier's ingredients occurs;
• re-prioritize or pause other related activities that are scheduled due to the identified non-conformance or incident;
• track samples and results related to and maintain audit records of all HACCP critical limit and other verification testing, allowing more rapid identification of batches or lots related to any potential incident;
• maintain all data and information, from R&D to final product QC, while leveraging a robust set of query tools to allow for more rapid examination of records for signs of deviation in a process or workflow;
• maintain records on recipes, as well as master and batch production records (though this functionality is more often the domain of a laboratory execution system [LES] or manufacturing execution system [MES]; a handful of LIMS may address this need, particularly since it's driven by HACCP rules); and
• provide a complete set of incident management and corrective action tracking tools that allow specific samples, analyses, personnel, batch numbers, suppliers, training events, and locations to be flagged as being tied to a particular incident file and corrective action plan, while also tracking and audit trailing all actions associated with the incident from start to completion.

These and other such LIMS functions should improve reaction time to non-conformances across the business.