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About PFI - Codes

CODE - PRODUCT CONTROL / POLICING

[A] QUARTERLY SAMPLING

STEP 1: Sampling

1.1 The PFI executive or a PFI member will on a regular basis or when necessary, on a quarterly basis:

a) Purchase a new product launched on the market or a reputed poor quality product
b) Purchase one other product from the competition.
c) ALL PURCHASES, by the PFI or by a member who suspects poor quality, must be of TWO bags from the same batch. One bag must be kept as a sealed bag until after the results are known. If the results are poor, Act 36/1947 inspectors will remove the sealed bag for official sample testing.

1.2 From the open bag, draw 3 x 100g samples.

1.3 Mark samples with the product name, bag analysis and other claiming statements.

1.4 The PFI member will either courier samples to the PFI office via the post office at their expense to:

The PFI
P O Box 1027
HILTON
3245
or, make arrangements with the PFI executive to collect the samples.

1.5 Any concerned pet owner or non-member may also send samples to the PFI.

STEP 2: Testing

2.1 PFI executive to select:

a) All suspected problem products.

b) A selection of 2 competitor products.

(Note: Selection to be on a rotational basis, according to a register of all PFI members.)

2.2 The PFI executive will supply the samples directly to an approved laboratory for analysis at the PFI’s cost. The remaining product samples and the sealed bag (if purchased) to be kept for future testing and as reference samples, pending the results, either by the PFI or the complainant.

2.3 The type of analysis required is to be requested by the PFI executive. This will, as a standard, mainly be protein, crude fibre, crude fat and ash for nutritional standard testing. Other tests may be performed upon request, provided there is justification.

2.4 If a PFI member company is requested by the PFI executive, to assist by doing analyses, these tests are at their own cost.

2.5 Results are to be kept confidential and returned to the PFI executive.

STEP 3:

3.1 PFI executive to collate data.

3.2 Problem products, identified from analysis received, are handled as follows: Take the remaining sample, if marginal and there is some doubt, and send to another PFI company or to an approved laboratory for additional testing.

3.3 If the PFI is satisfied that the results are out of specification for product belonging to non-members of the PFI, write a letter to:

a) Act 36 Registrar, registering an official complaint.

b) The company whose product was tested advising them of the testing, the results and the notification to the Registrar.

If the product is from a member of the PFI, write a letter to:
c) The PFI member / company whose product has been tested. (NOTE: withhold the letter to Act 36 Registrar if the sample is from a PFI member. The PFI member is to be given time to rectify the problem as per steps 4 and 5 below before notifying the Registrar Act 36)
The letter must inform both of them of the results and the problems.

Non-Members' Product

3.4 Arrangements must be made with Act 36/1947 Inspectors to take official samples from the sealed bag. This bag is the property of the PFI and the complaint legally would be registered against the PFI. Act 36/1947 will proceed with the legal process as determined in the Act.

PFI Members' Product

3.5 A problem member company will be given time to rectify its products, and informed that re-sampling will take place in 60 days. (Samples will be taken by the PFI executive, either in the market place, or at the manufacturing plant).

3.6 The 60-day sample may be tested at any one of the approved laboratories (NLO, ARC, CAL and/or PMB University)

3.7 If the product is still out of specification, inform the company that the problem still continues, and request Act 36 to schedule a plant visit. All product at the company to be sampled, tested and reported.

3.8 If products are found to be out of specification, the company must submit product samples from product produced for a period of 1 month, to be tested continuously to ensure that it remains within specifications. Act 36 is to be supported in the analyses they require.

3.9 If the product is found to be out of specification, request the Registrar to ensure the product is withdrawn from the market place.

3.10 If this is not carried out, PFI is to liase with the Registrar Act 36 to ensure that prosecution is pursued. But if the product is found to be within specification, a written warning must be served.

3.11 If the product conforms, a 90-day specification check is to be carried out. If the product is “ok”, no further action will be taken. If the product is “not ok”, move straight to Prosecution process as per point 3.9.

STEP 4:

4.1 Testing during Step 3 period can be assisted by PFI companies to reduce cost on the Registrar, although samples taken as per point 3.8 will be charged to the company under test as per the Regulations of Act 36.

[B] OTHER AVENUES OF PROCESS
Consumer complaints and product claims

A PFI member can require that a product test is performed according to the steps outlined above, so as to substantiate consumer complaints or product claims.

[C] PACKAGING, ADVERTISING AND LABEL COMPLAINTS

All complaints with respect to packaging, advertising and label complaints, where these do not conform to Act 36 or standard advertising standards, may be brought to the attention of the PFI executive. Submit samples of the material against which the complaint has been raised, to the PFI. The PFI executive needs to check that in terms of Act 36 Regulations there is a valid complaint.

a) PFI members
Where this involves a PFI member and the complainant is a PFI member, the complainant can choose to:

(i) first address the complaint directly with the alleged defaulter; or

(ii) request the PFI executive to address the complaint to the alleged defaulter.

If no positive corrective action is forthcoming (using the time frames as for specification/analytical complaints) then the PFI executive must address the complaint in writing to the Act 36 Registrar for his attention and action. (The PFI executive has an agreed procedure with the Act 36 Registrar in terms of lodging complaints, follow-up on progress with complaints lodged, and report back on the outcome of the action taken with respect to the complaint) All correspondence to the Act 36 Registrar must be copied immediately to the alleged defaulter.

b) Non-PFI members
A complaint regarding a non-member of the PFI must be brought to the PFI executive. In this case the PFI executive will, in writing, inform the Act 36 Registrar of the substance of the complaint directly, and copy this correspondence together with a letter, to the alleged defaulter.