FSIS continues to put increased responsibility for correct labeling on you, the processor. The generic labeling program exempts many labels from review and approval in Washington, DC – making you entirely responsible for accuracy, completion, and adequate record keeping. The new procedures for review of labels submitted to Labeling and Consumer Protection Staff (LCPS) for approval will give a clear advantage to any application that is complete and has any potential problems resolved prior to submission. If you expect to obtain timely label approvals under the new label approval system and sail smoothly through audit of your generic labels, the following four "power tools" for labeling are indispensable. - Training.
Know the label approval system, its rules and requirements. Give your staff the benefit of a solid grounding in labeling: Prime Label's Basic Course in Standards and Labeling Requirements for Meat and Poultry Products, its Course in Nutrition Labeling for FDA- and USDA-regulated food products, and participation in the customized Labeling Certification Program. - Software.
A user-friendly package that virtually assures a complete, accurate label approval application is a must. Only one product has it all: EZ Form® software for Windows. And only EZ Form® organizes and maintains the records you need for all your label approvals, both generic and granted by LCPS. - Expert advice.
Many of the guidelines Labeling and Consumer Protection Staff personnel follow are not in general circulation. Even the published sources tend to be ambiguous and confusing. When you have a question, go to an experienced consultant (any of Prime Label’s seasoned food technologists will do) – someone who knows things only a person with years of daily exposure to labeling issues and LCPS procedures can know. - A top-notch expediter/consultant.
If you think that the procedural changes at LCPS mean there’s no advantage to having an expediter/consultant in your corner, you’re mistaken. A superior expediter/consultant is still your best ally in obtaining rapid, accurate label approvals. Prime Label Consultants can: - Pre-screen your application to assure completeness (a problem that can result in immediate return of your application without review).
- Intercept problems and resolve them according to your wishes. The new procedures put no limits on the types of changes reviewers can make without your feedback. Your PLC food technologist can identify most problems during pre-screening, and will consult with you and LCPS to reach a satisfactory solution.
- Submit your application in person directly to the Distribution Unit, obtaining proof of receipt and assuring proper position in queue – avoiding potential delays or losses.
- Assure correct initial routing of your application.
- Quickly retrieve, correct and resubmit applications requiring corrections, rapidly placing them back on the path for approval. Of course, all changes will be made according to your wishes.
The race for label approval will go to the strongest competitors. Contact PLC for more information on how our unique "power tools" can maintain your competitive edge in the labeling arena. |
