Is there any risk to the quality director?

It's already a group, and basically there will be qualified employees. On the contrary, there are many small customers or brands, and it is difficult to recruit quality and safety leaders. The problem still exists.

This question comes from 19, and many answers are time-sensitive, that is, after 202 1, the nominal quality supervisor is unreliable and risky, and your salary can be higher.

Personal requirements are relatively high, bachelor degree or above, more than 5 years of work experience, professional requirements. At present, the industry is very short of such talents. Big brands have talents, and it is difficult for small factories to find such talents. They are all paid more than 20 thousand.

The person in charge of quality and the legal person will bear certain economic responsibilities, and serious violations will even be subject to criminal punishment. This is no joke. There was no strict requirement for this before. Now it is clear that the person who finds the right one is the person in charge of quality and the legal person. Don't borrow it indiscriminately, and get the corresponding return from the market if you want to call it.

According to the Regulations on the Supervision and Administration of Cosmetics (hereinafter referred to as the Regulations) and the Measures for the Supervision and Administration of Cosmetics Production and Operation (hereinafter referred to as the Measures), the Cosmetics Supervision Department of the State Medical Device Administration sorted out the main concerns of the cosmetics industry during the implementation of the Measures and answered them one by one. Details are as follows:

Question 1: Can the person in charge of quality and safety hold concurrent positions in different cosmetic registrants, filers and commissioned production enterprises?

A: In order to ensure the quality and safety of cosmetics and ensure that the person in charge of quality and safety performs the duties of product quality and safety management and product release according to law, two or more cosmetics production licenses are applied according to the principle of "one certificate and one person", and the same natural person may not be the person in charge of quality and safety of the above-mentioned enterprises; The person in charge of quality and safety of different cosmetics registrants and filers shall not be the same natural person. Cosmetic registrants, filers and commissioned production enterprises belong to the same group company and implement the same quality management system. When a registered person or a filing person entrusts the production of cosmetics, the registered person, the filing person and the entrusted production enterprise may employ the same natural person as the person in charge of quality and safety.

Question 2: Can the person in charge of quality and safety authorize others to perform their duties on their behalf?

A: Article 28 of the Measures stipulates that the person in charge of quality and safety shall, in accordance with the requirements of the responsibility system for cosmetics quality and safety, assist cosmetics registrants, filers, legal representatives of entrusted production enterprises and principal responsible persons to undertake corresponding product quality and safety management and product release responsibilities. According to the needs of cosmetics registrants, filers and entrusted production enterprises in the operation of production quality management system, with the written consent of the legal representative or principal responsible person, the person in charge of quality and safety may authorize others to perform their duties on their behalf. The authorized person shall have the corresponding qualifications and abilities to perform his duties. The time, personnel and matters authorized by the person in charge of quality and safety shall be truthfully recorded to ensure the traceability of authorization. The person in charge of quality and safety shall supervise the authorized person to perform his duties, and the legal responsibilities he should bear shall not be transferred to the authorized person.

Question 3: How to correctly understand that "the production process of labels should be completed in the cosmetics production enterprise that has completed the last production process in contact with cosmetic contents"?

A: Article 63 of the Measures stipulates that the production process of cosmetic labels should be completed in the cosmetic production enterprise that has completed the last production process of contacting cosmetic contents. The legislative intent of this clause is to prohibit cosmetics from leaving the factory before the product label is completed, making the product untraceable. In this paper, "the production process of cosmetic labels" refers to the production process of labeling packaging materials that come into contact with cosmetic contents. It is worth noting that under the premise that the production process of labeling the original packaging of imported cosmetics has been completed and traceable, the cosmetics production enterprises that have completed the last production process of contacting the contents of cosmetics may not be able to complete the Chinese labeling behavior.

Question 4: Who are the people directly engaged in cosmetics production? What are the diseases that hinder the quality and safety of cosmetics stipulated by the health authorities in the State Council?

A: The scope of "personnel directly engaged in cosmetics production activities" stipulated in the Regulations is determined according to the actual situation, and in principle, it should include operators engaged in cosmetics production, inspection and storage. Such employees should undergo health examination before and during their employment, and they can only take up their posts after obtaining a medical report with complete inspection items and clear conclusions issued by medical institutions.

According to the "Regulations", the scope of diseases that hinder the quality and safety of cosmetics shall be stipulated by the health authorities in the State Council. Before the relevant regulations are issued by the health authorities in the State Council, the scope of diseases that hinder the quality and safety of cosmetics stipulated in the original Regulations on Hygiene Supervision of Cosmetics shall be implemented, including dysentery, typhoid fever, viral hepatitis, active tuberculosis, hand dermatoses (tinea manus, onychomycosis, hand eczema, psoriasis or scales occurring in hands) and exudative dermatoses. People with these diseases cannot directly engage in cosmetics production activities.

Question 5: Should cosmetic operators establish and implement a product sales record system?

A: According to the "Regulations" and the "Measures", cosmetics registrants, filers and entrusted production enterprises should establish and implement a product sales record system. Cosmetic operators such as shopping malls and supermarkets have no obligation to establish and implement the product sales record system, but they should take effective measures to ensure the traceability of products. Cosmetic operators are encouraged to establish and implement a product sales record system if their sales targets are other cosmetic operators.

Question 6: Are beauty salons, hotels, etc. OK? Prepare and fill cosmetics?

A: Beauty salons, hotels, etc. Those who use cosmetics in business or provide cosmetics for consumers shall fulfill the obligations of cosmetics operators stipulated in the Regulations and these Measures according to law, and the cosmetics they provide to consumers shall meet the requirements of the minimum sales unit label.

According to the provisions of the Measures, the preparation, filling and filling of cosmetic contents shall obtain a cosmetic production license. Beauty salons and other institutions are not allowed to prepare cosmetics by themselves, nor are they allowed to fill or fill cosmetics without authorization, except that cosmetics are prepared on the spot for consumers to use according to the usage methods in the cosmetics label or instructions. Cosmetics provided to consumers by hotels, bath centers, wedding photo studios and moon center should have product labels that meet the requirements. The label shall be marked with the product name, the special registration certificate number for cosmetics, the name and address of the registrant, the filer, the entrusted production enterprise, the cosmetics production license number, the product implementation standard number, the total composition, the net content, the use period, the use method and the necessary safety warning, as well as other contents that should be marked according to laws, administrative regulations and mandatory national standards.