Written by Douglas C. Fair
Principal Statistician
StatPros Consulting
The Goldilocks principle refers to the concept of “just the right amount.” In the case of food and beverage manufacturers, filling their packaging with content can be as difficult as navigating a house with three bears. Much like the fairy tale, there can be different endings to your story; get eaten by the consequences of either underfilling or overfilling or escape unharmed, maximizing profits and minimizing waste by filling content “just right.” Luckily for you, Minitab knows how to handle the bear traps of filling.
Food and beverage manufacturers are required to adhere to strict regulations regarding product weight and fill levels. These are generally referred to as “Net Content Control” regulations. These important consumer protection laws concern the amount of product that is actually contained in the package, as compared with what the external packaging states that it should contain. These laws help guide manufacturers and ensure consumer protection while maintaining market integrity.
Around the globe, regulators hold manufacturers responsible for “misbranding,” defining it as packaging or labeling that is false or misleading in any way. While this clearly has a broad scope, underfilling not only puts a company at risk for things like warning letters, fines, potential injunctions or even criminal charges from regulators, but it also puts a company at risk for class-action lawsuits from customers.
But wait, there’s more. In the United States, there’s also a concept called slack fill, which regulates how containers are filled. These laws are meant to prevent the sale of partially filled containers that might mislead consumers about the amount of product in a package.
The U.S. Food and Drug Administration (FDA) defines nonfunctional slack fill as the difference between the capacity of a container and the volume of product inside. Whether North America or Europe, consumer protections are enforced to ensure manufacturers do not mislead or “short” consumers.
Slack fill lawsuits have been filed against food and beverage makers who left empty space in a container for reasons other than functional ones, such as protecting contents or complying with shipping requirements. The argument by regulators here is that even if you put the proper fill weight on the label, largely unfilled packaging is also misleading.
Manufacturers are interested in doing right by both consumers and regulatory agencies. This has resulted in additional technological investments by organizations to minimize the potential for underfilled packages. Most food filling lines are equipped to automatically remove and destroy underfilled packages, ensuring only those that comply with package requirements’ minimum weights make it to store shelves. Together, the technological investments and automated elimination of underfilled packages are the result of too much uncontrolled manufacturing variation, without which costs could be lower for both manufacturers and consumers.
Regardless of if you’re trying to meet minimum fill weights, avoid nonfunctional slack fill, or reduce the costs of uncontrolled variation, Minitab’s Real-Time SPC solution can help. Whether it’s monitoring process stability or delivering alerts when fill weights might violate governmental regulations, Real-Time SPC is the most cost-effective and efficient way for food and beverage manufacturers to solve these problems.
If you aren’t using Real-Time SPC and you’re wondering why you’ve been blissfully successful in avoiding underfilling, I have some bad news: your folks are most likely purposefully overfilling. This happens so frequently, that there’s even a name for the excess – appropriately called “giveaway.” Generally, “giveaway” is the result of managerial good intentions: “Let’s NOT underfill, and let’s NOT violate any regulations.”
There are two fundamental problems with “giveaway.” The first one is obvious, everything that is overfilled increases the cost of goods and lowers profits. The second one is worse: often overfilling is a means to cover up an unstable process with a lot of variation. However, this not only eats into profits, but doesn’t actually make the process capable, thereby still creating exposure to the possibility of underfilling. That means you’re actually paying more without even mitigating risk!
Two distinct problems often require two different solutions, but in this case Real-Time SPC can address both. Whether you’re looking to monitor and alert for underfilling or looking to stabilize a process to eliminate the need for overfilling, Real-Time SPC can be applied. Remember, if you’re not doing statistical process control, you’re either accepting the risk of severe consequences of underfilling, or you have become comfortable with overfilling and losing potential profits.