11 replies to this topic

[SaraTrops]

Hello everybody!

 

I´m a little bit confuse with how to do a risk assesment of packaging. Can someone help me?

 

Thank you.

[Tony-C]

Hi Sara,

 

 

An important question here is if the packaging you are talking about is in contact with the food so the first aspect of you risk assessment maybe categorising your packaging into food contact (primary packaging) and non-food contact (secondary packaging).

 

Here are the requirements in the BRC standard:

3.5.1.1 The company shall undertake a documented risk assessment of each raw material or group of raw materials including packaging to identify potential risks to product safety, legality and quality. This shall take into account the potential for:
• allergen contamination
• foreign-body risks
• microbiological contamination
• chemical contamination
• substitution or fraud (see clause 5.4.2).
Consideration shall also be given to the significance of a raw material to the quality of the final product.
The risk assessment shall form the basis for the raw material acceptance and testing procedure and for the processes adopted for supplier approval and monitoring. The risk assessments shall be reviewed at least annually.

BRC Interpretation Guideline Raw material risk assessment:
All proposed ingredients and packaging must be subjected to a documented assessment of their inherent risk. This may form part of the HACCP plan;

 

So your Hazard Analysis can demonstrate an assessment. You may also consider historical evidence of the supplier and raw material and customer or legislative requirements.

 

For packaging there might be risk of micro contamination, foreign bodies and chemical migration for example so you will need to consider the risks of any hazards you identify and apply controls measures such as requiring chemical migration certificates.

 

Kind regards,

 

Tony

[Anika]

Hello everybody!

 

I´m a little bit confuse with how to do a risk assesment of packaging. Can someone help me?

 

Thank you.

Hi Sara,

 

Agree with Tony, except, I don't think you need the VACCP part (substitution or fraud) for Packaging (primary or secondary).

 

Check out some of the other discussion regarding this:

 

http://www.ifsqn.com...-materials-542/

http://www.ifsqn.com...ier/#entry86732

[Simon]

Well at the provided links form the horses mouth not required to assess packaging for substitution or fraud.

 

What about malicious tampering or contamination...I think yes.

[Charles.C]

Well at the provided links form the horses mouth not required to assess packaging for substitution or fraud.

 

What about malicious tampering or contamination...I think yes.

 

For this topic an absolute hotchpotch of acronyms / terminologies / interpretations now exists from various sources, eg BRC, PAS96, GFSI, USFDA, etc which includes VACCP, TACCP, HACCP, Food Fraud, Vulnerability Assessment [VA], Threat Assessment, Food Defense, Food Defence, EMA , and no doubt others.

 

BRC7 is primarily using GFSI approach so that malicious activities are not included in Food FraudVulnerability Assessment ( PAS96  includes  both Food Fraud and  malicious activities within TACCP and makes no references to VACCP [although it includes vulnerability assessment]).

 

BRC7 includes malicious activities in Food Defence (defined as - Procedures adopted to assure the safety of raw materials and products from malicious contamination or theft). Whether that includes packaging, probably Yes from the wording.

 

 GFSI - HACCP vs TACCP vs VACCP.2.jpg   48.85KB   9 downloads

http://foodfraud.msu...sessment-vaccp/

 

PS - might mention that GFSI does include packaging in its definition/scope of "food fraud" plus there are a few publications which have specifically considered related risks. IIRC the official inclusion in GFSI Standard was projected to be considered for 2016 version. Seems BRC have so far simply chosen to opt out but if it's benchmarked, hmmm. BRC8 perhaps.

[SaraTrops]

Thanks everybody!!

 

My company works with mangos and avocados and my question is mainly about packaging into food contact (primary packaging).

I have already ask to all our suppliers about quality certificates, health registration, technical data sheets, migration analysis etc. 

The thing is that I don´t know how to start the risk assesment (this is the first time that I do one).

Our main packiging material is cardboard packages and plastic boxes and film.

[Charles.C]

Hi Sara,

 

Have a look at the excel sheet in this post and surrounding thread which responds to yr query but for food -

 

http://www.ifsqn.com...511/#entry52714

 

This was for BRC6 but should be adaptable for packaging (packaging was aded in BRC7 IIRC). It approx. matches post 2 bar the food fraud which you don't need anyway

 

You need the data to go with it of course. 

 

I hope that at a minimum yr packaging is certified as food-grade.

 

There are various posts/threads here on this topic, mostly for food but maybe some for packaging.

 

Here is another one for food -

 

http://www.ifsqn.com...ier/#entry86714

[Charles.C]

addendum

 

this one was for packaging, eg post 8, it's a bit laborious due to all the previously posted "helps" involved

 

http://www.ifsqn.com...-for-packaging/

 

Another recent "update" IIRC is that suppliers are confirmed to be able to use 3rd party audit certificates from non-GFSI recognized companies.

[Tony-C]

Thanks everybody!!

 

My company works with mangos and avocados and my question is mainly about packaging into food contact (primary packaging).

I have already ask to all our suppliers about quality certificates, health registration, technical data sheets, migration analysis etc. 

The thing is that I don´t know how to start the risk assesment (this is the first time that I do one).

Our main packiging material is cardboard packages and plastic boxes and film.

 

Hi Sara,

 

Here is a quick draft to give you an idea:

 

 Packaging Risk Assessment.jpg   140.94KB   12 downloads

 

Kind regards,

 

Tony

[Charles.C]

Hi Tony,

 

Interesting document. Thks.

 

One query - i deduce the 3 risk columns are intended for safety ? (despite Y&M).

How does the layout respond to the quality and legality aspects ? Via (sometime) tested compliance to a (Food-Grade?) Specification and Approved Supplier Status? (IMEX, COAs are rare for packaging )

(I might add that some export customers IMEX have peculiar local regulatory, legality, requirements)

[Tony-C]

Hi Charles,

 

This is a specific example, chemical migration is just as likely a question of legality, I couldn't think of a quality risk to the final product.

 

On the whole you would need to consider in conjunction with:

Supplier approval and ongoing monitoring
Controls on the acceptance of raw materials
Specifications - for all raw materials, including packaging materials, must be provided and adequately detailed. They must include the defined limits for all parameters critical to the safety, legality and quality of the product.

 

Kind regards,

 

Tony
 

[djammur]

^{my company deals with labels and packets.  We started with raw materials, such as film, paper, inks, adhesives.  Once we were done with that, we moved on to machinery (presses) then to packaging.}

^{It was so much easier for us doing it that way.}