It is inevitable. In business, some customers will not be satisfied with the quality or value of the product or service they receive. How a company addresses customer questions, complaints, and rejections is essential to their success. This is especially true in the third party cannabis and hemp testing industry where the landscape is obscured by evolving governmental regulation, a lack of industry standards, customers willing to lab shop, and test labs willing to compromise their integrity for profits.
Anticipating failure is crucial to any business. As such, planning for failure is a component of certified quality management systems and product approval processes. Acknowledging things can go wrong at an independent testing facility provides processors and producers with an opportunity to discuss this sensitive topic with potential third party test labs. Evaluating a lab’s corrective action process should be central to evaluating any potential service provider. While there are many details to audit, the review boils down to two main components: methodology and philosophy.
It is relatively easy to audit for methodology. Start by only working with companies that are both ISO 17025 and ISO 9001 certified. Both certifications are equally important; research and understand the difference.
ISO 9001 mandates that companies will have a process for addressing customer complaints. An audit of a lab’s quality system should include auditing their procedure for Customer-Initiated Corrective Actions. A comprehensive quality management system utilizes a process accepted across industries like 8D, a team-based approach to investigate discrepancies and escapes. 8D utilizes a series of steps to identify the root cause of a problem and for implementing and evaluating corrective actions. Understanding the process for investigating discrepancies and initiating corrective actions is important, however a company’s actual commitment to the process is more difficult to discern.
While it takes effort to understand a lab’s culture and philosophy, it is critical to the evaluation process. Writing and implementing procedures is not difficult. Committing to following procedures and imbuing a culture of quality into a company are much more difficult. A lab with a “culture of quality” understands that no system is perfect and strives to find where it can improve. This is especially true when it comes to customer complaints and investigating their own processes for flaws.
Of all the things that can go wrong, the most egregious error that occurs in business is failure to admit something could go wrong. The testing lab is supposed to be the impartial arbiter. Guided by science and process, the testing lab is trusted to return accurate, impartial results. Having a process for starting customer-initiated corrective actions is only part of creating a culture of continuous improvement. In an industry that is still developing its standards and guidelines, investigating the root cause of discrepancies generates valuable data.
For example, there are no industry established protocols for taking and preparing samples. Aggressive root cause analysis could help identify trends different variables have throughout the entire process of taking and testing samples, from the size of the sample, to the temperature the lab retains samples at after initial testing.
Test lab customers primarily come from two streams, farmers and processors. Processors performing extraction or creating value-added products often have some internal testing capability, allowing them to monitor product quality throughout the manufacturing process. When processors evaluate test labs the value of transparency cannot be overstated. For example, is the test lab willing to share their test procedures? If a processor and test lab can run identical tests on identical equipment, it reduces the potential for discrepancy and makes any investigation easier to conduct.
Many processors utilize multiple testing facilities. One method for evaluating labs is to send a known sample for testing. Obviously high marks are given to labs returning accurate results. But how do you investigate a lab’s philosophy about corrective actions? If one of labs provides inaccurate results, initiate a corrective action. This is a real time opportunity to evaluate a test lab’s quality system and philosophy. Do they actually undertake an investigation? Do they allow you to participate?
Evaluating the corrective action ability of a lab who returns an accurate test result is not as clear cut. They may share their procedure, but are they willing to share some of their historical data? Will they allow an audit of their corrective actions log? During the evaluation process did the topic of corrective actions even come up?
From the lab’s perspective, the lack of industry established test standards and practices makes a robust investigative process critical to adequately address customer concerns and cover your company’s assets. In a culture of continuous improvement, a customer-triggered investigation is viewed as an opportunity. Performed properly, it presents an opportunity to reset the relationship with the customer. The lab can use the corrective action request to educate their customer about lab processes and coordinate with the customer’s staff that are performing similar functions. An effectively conducted investigation helps identify and eliminate weaknesses in the testing process and enhances the lab/customer relationship.
This type of culture is created from the top down. The top level of an organization (ownership, executive management) must nurture a culture that understands that the best systems and the best people are not perfect. Executive management creates an environment where investigation and corrective actions aren’t punitive, but create potential value for the company.
Finally, it takes a conscious effort to create a culture that can investigate a complaint impartially. Upper management must demonstrate their commitment through empowerment on multiple levels. The process must be empowered. Upper management has to allow the investigative process to take its natural course without trying to influence it. The team leader and all members of the team must be allowed to conduct the investigation independently and follow the objective evidence to its source. Cultivating a corporate culture that views investigating a discrepancy as an opportunity for continuous improvement creates a culture of trust both inside the lab and with customers.
Dan Isenstein was an executive in the injection molding industry for 20 years. His experience includes participating with the development, implementation, and maintenance of the company’s ISO program. More recently Mr. Isenstein had his first book, Tales from the Kentucky Hemp Highway, published by The History Press. The book is a narrative history of the Kentucky hemp industry from 1775 until the current day. Dan also represents a test lab in western Pennsylvania and would love to discuss your testing needs.
