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How did NIST came up with their MAV tables for FDA products?

Started by , Sep 11 2020 03:19 PM
4 Replies

Does anyone know how NIST came up with their MAV tables for FDA products? We have a puff pastry product that we only sell to other manufacturers, and the net weight is 24lbs per package, and under the NIST table, the maximum we can deviate is 0.37lbs, which is only 1.5% of the total weight! This seems overly restrictive to me, because lower weight products AND products over 54.5lbs have a higher % weight deviation allowed. I mostly just wanted to rant about this but if anyone does have an explanation I would appreciate that as well :)

 

Best,

Caleb

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Can you not achieve that tolerance?  If you read through the NIST handbook I'm sure there is a source for the values.

 

Maybe it is time to look at better process control to achieve that tolerance.

On speaking with R&D, it has to do with the nature of the product and the machinery used. Variations in the thickness of the dough get introduced by things like roller and belt speed, roller compression, that the dough also has a tendency to spring back after it goes through the sheeter, and how much it retracts depends on how long the dough sits before being cut. The dough gets cut into sheets of uniform area, and the variance from each sheet is compounded because each container has several sheets.

 

Is there any way around this? Do our machines/processes just suck?

Well, usually it isn't an issue if you are over the net weight limit, moreso on being under.  So I would imagine if you can steer towards the higher end you will be fine.

 

But yes, it does sound like your equipment may not be up to snuff, or that it is something that hasn't really been controlled that well.  If you can justify with the cost of wasting product by making them heavier / larger than required you can get better process control with equipment upgrades, or changes in procedures.

 

Is this something that's been discussed before?  Or are you the first to broach this subject at the company?  If you are the first, then I imagine it is just something that no one really looked at that hard or even cared about.

As far as I know, I am the first to bring it up. I guess I will make everyone aware of the regulatory reqs and they can do what they will! Thanks Ryan!

 

Caleb


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