Kimberley Loyza. Kraft Foods Group, Inc.

Transcription

1 Kimberley Loyza

2 2

3 Interspec Implementation (prior to 2012) 67 Countries 21 stand-alone applications 3100 users Interspec COMPLEX! Different regulations from country to country Different legacy systems Different processes and ways of working Different languages 3

4 Some Global Challenges and Solutions Frame Design The specification frames were designed (and redesigned!) to incorporate all of the required information across the different countries and regions. Languages Work was completed with the regions to help incorporate different languages into the frames as well as data content. 4

5 Ingredient Line Module Synonyms are configured in the system to allow each region to declare ingredients according to local regulations. Nutrition Module REF (Reference) Specs are set up to house the differences between nutrient definitions, nutrient daily guidelines (%DV, %GDA) and rounding rules. 5

6 Ongoing Maintenance Global councils met to set up clear guidelines for each picklist within the system. For example, Base Names cannot have a synonym more specific than the base name All lists from legacy systems were reviewed against these guidelines before the initial load. For on-going maintenance, each request for a pick-list addition is filtered through the subject matter expert(s) to ensure that it meets the guidelines. Pick-lists undergo health checks on a regular basis the better the data in, the better the data out! 6

7 Continued Simplification Reviewing all data to ensure that it is still relevant and that it is still captured appropriately. Reducing fields to help ensure that the appropriate data is captured and that extraneous data is not a time-waster. Evolving spec model: Regulatory spec initially set up to capture regulatory labeling requirements. This model was not practical once implementation began and all data now resides on PROD specs. Packaging Assemblies moved to unique specifications during implementation. This became too burdensome and work is being done to move back to more generic specs. 7

8 Business Process R&D enters/updates Formula Regulatory runs Ingredient Line Module & Positive/Negative Module Regulatory runs Nutrition Module & uses that saved panel to run Food Claims Module The Modules are often run to assess the impact of a change or to validate that a formula meets specific requirements. These may be run by R&D although the final panel that is exported into the spec must be completed by Regulatory. All saved panels are exported to specifications Regulatory completes additional label copy R&D approves spec 8

9 Food Claims

10 The Food Claims Challenge Claims that food companies make on their products are regulated and can be complex. Each country or region may have its own set of regulations determining what can be said about a product depending on its nutrition profile as well as, in some cases, its ingredients. 10

11 US Examples 11

12 Canada Examples 12

13 Saturated Fat Free <0.2g Saturated Fat and <0.2g Trans Fat per Serving and RA Saturated Fat Free <0.5g Saturated Fat and <0.5g Trans Fat per Serving and RA Saturated Fat Free Saturated Fat + Trans Fat <0.1g per 100g 13

14 Options 1. Review every claim manually, according to local regulations, based on the system generated nutrition information. Requires calculating to different amounts i.e. serving sizes, reference amounts, 50g, 100g 2. Have the system do the work! 14

15 Food Claims Module

16 Deconstructing the Claims Each claim was broken down into its basic requirements. From the example below, 1 claim was broken into 3 separate sets of requirements characterized by the Region, Food Type and/or Reference Amount. 16

17 Creating the Building Blocks Each of these identified requirements was then configured as a Criteria Rule Condition in the Food Claims Configuration. Over 1500 unique conditions were identified. 17

18 Configure the Rules The Criteria Rule Conditions are combined using basic AND/OR logic to create the Criteria Rules. These are still unique to a specific criteria set i.e. Region, Reference Amount, Food Type. 18

19 A more complex example Nutrient Condition Manual Conditions Claims Conditions 19

20 Assigning to claim 20

21 Using the Module Regulatory uses the Food Claims Module to assess that a formula meets the regulatory requirements to make a food claim on a package. The Food Claims Module is also used to inform Regulatory of any additional labeling requirements triggered by the claim. For example, referral statement requirements for Fat, Saturated Fat, Sodium and Cholesterol have specific conditions that the system can evaluate. 21

22 In the Module Food Type allows you to select Food, Meal, Liquid Reference Amount is entered by user and is an important factor for many claims 22

23 A region is selected to narrow claims to that country Additional Key Words help analyze products against specific requirements List of claims unique to region / category selected above Manual claims require user input to help determine outcome of claim 23

24 Detailed Results 24

25 Alerts/Labels Alerts do not appear in the final text to be exported to the specification. This is for information only and serves as a watch-out to regulatory users. 25 Labels appear in the final text to be exported to the specification. This is a referral statement required under specific conditions that the system evaluates.

26 Beyond Any numeric data point that can be captured at the raw material level and rolled up through the nutrition module can be evaluated against criteria in the Food Claims Module For example: residue limits, active principles (estragol, menthofuran) 26

27 Lessons Learned The Food Claims Module was difficult to implement as the learning curve for the configuration was very long. The ability to configure claims required both systems knowledge (how to put the building blocks together) and claims knowledge (what behaviour/results am I expecting from the module). What worked? Changes were made in the configurator and then the module was run to verify the outcome. Once the configuration was learned, it was easy to continue adding more claims, more countries, more categories etc. Maintenance is flexible if a regulation changes it is easy to adjust the conditions to reflect this. Overall, the Food Claims Module takes time and hard work to set up but it is powerful and useful when done!! 27