14 replies to this topic

[Jess S]

Hello all,

 

Do any of you have any ideas on how to assess the vulnerability of packaging?  I completed a vulnerability assessment of all raw food products as required under section 5.4.2, but was completely caught off guard when the auditor asked for our assessment on packaging claiming that is required under section 3.5.1.1.    I am completely at a loss with where to begin in the packaging arena.  Any ideas?

[trubertq]

Start with close contact packaging. Are all your suppliers BRC/IOP certified, if not, have you completed a site audit? Can the packaging be substituted by something else? How long is the supply chain, are there weak points within it? What are your goods inwards checks like? Would they pick up on fraudulent packaging ?

[Charles.C]

Hello all,

 

Do any of you have any ideas on how to assess the vulnerability of packaging?  I completed a vulnerability assessment of all raw food products as required under section 5.4.2, but was completely caught off guard when the auditor asked for our assessment on packaging claiming that is required under section 3.5.1.1.    I am completely at a loss with where to begin in the packaging arena.  Any ideas?

 

Hi Jess,

 

Unless something has changed in the very, very, recent past, BRC do not require a VA for packaging.

 

This has been previously discussed here at some length.

[Jess S]

I, too, was under the impression that BRC did not require a VA for packaging, but as I said, the auditor asked me for one.  Although we were given grace this time, I think that if that same auditor comes back he will expect it to be added for next time.  This caught me completely off guard!

[Charles.C]

I, too, was under the impression that BRC did not require a VA for packaging, but as I said, the auditor asked me for one.  Although we were given grace this time, I think that if that same auditor comes back he will expect it to be added for next time.  This caught me completely off guard!

Hi Jess,

 

Indeed, the wording in the Standard has created some confusion.

 

Perhaps yr auditor does not regularly read BRC's monthly newsletter.  

 

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

 

Of course, the expectation (or lack of) a VA may also reflect the relative extent of reported food fraud ascribed to "Packaging" ?

 

Regardless, BRC may have to follow GFSI's lead.

[Sharone]

Hi Jess,  

I am in the process of doing a vulnerability assessment on our raw materials, but am struggling a bit.  If you don't mind, could you please share your template/assessment for ideas?

 

Regards

 

Sharon

[CMHeywood]

I assume Jess is talking about the packaging that his/her company uses, not the packaging used by their suppliers.

I have previously assumed that fraudulent packaging meant that the product did not match what the package said.

What are some examples where people thought they were getting fraudulent packaging - jars, boxes, cans, films, etc.? 

This would be packaging as a raw material and not a finished product where the description on the package doesn't match what the product really is.

[Charles.C]

I assume Jess is talking about the packaging that his/her company uses, not the packaging used by their suppliers.

I have previously assumed that fraudulent packaging meant that the product did not match what the package said.

What are some examples where people thought they were getting fraudulent packaging - jars, boxes, cans, films, etc.? 

This would be packaging as a raw material and not a finished product where the description on the package doesn't match what the product really is.

 

Hi CMHeywood,

 

I suggest most people are simply grateful for the info. in Post 5

 

Not that i would wish to prevent anyone enjoying yet another BRC risk assessments.

[redfox]

 Hello,

 

In BRC v7 clause 3.5.1.1, packaging of finished product is mention to have VA. But in clause 5.4.2 only raw materials is mentioned. Quite confusing. But NSF audit guidelines mentions in their Food Defense audit checklist requiring the site to have VA in their finished product packaging.

 

Food Safety Expectation and Criteria for Food Processing Faciities_May 2014

 

Regards,

redfox

[Charles.C]

 Hello,

 

In BRC v7 clause 3.5.1.1, packaging of finished product is mention to have VA. But in clause 5.4.2 only raw materials is mentioned. Quite confusing. But NSF audit guidelines mentions in their Food Defense audit checklist requiring the site to have VA in their finished product packaging.

 

Food Safety Expectation and Criteria for Food Processing Faciities_May 2014

 

Regards,

redfox

 

For BRC, see the link in Post 5.

[Jess S]

Hi Jess,  

I am in the process of doing a vulnerability assessment on our raw materials, but am struggling a bit.  If you don't mind, could you please share your template/assessment for ideas?

 

Regards

 

Sharon

 

Hi Sharon,

 

I was in the same boat that you are in with not knowing where to begin.  If you look up Proposed Vulnerability Assessment, BRC7, 5.4.2 within the ifsqn site, you will see that Charles C put together an amazingly helpful template back in November 2015.  For the most part, I went right off of that template.   I did choose, however, to do my evaluation in raw material groups as I do believe that it would have taken me forever if I did each and every ingredient individually.  NOTE:  when I  say groups, I lumped together all of my spice blends in a group, vinegars in a group, oils in a group, etc.  That is not saying that I didn't call out issues by item, but for the most part items in the group are pretty similar.

 

Regards,

Jess

[trubertq]

I was asked for a VA for packaging in the audit last week.

[Charles.C]

I was asked for a VA for packaging in the audit last week.

 

Hi trubertq,

 

interesting.

 

Did you refer the auditor to BRC's newsletter / BRC Participate ?

[trubertq]

I didn't have to since I had the vulnerability study done. Furthermore, in the middle of an audit BRC newsletters are not foremost in my mind.

[Charles.C]

I didn't have to since I had the vulnerability study done. Furthermore, in the middle of an audit BRC newsletters are not foremost in my mind.

 

Hi trubertq,

 

At least you have proven that some BRC auditors are apparently still unaware of the BRC7 requirements.

Let us hope that BRC read yr post.

 

Thanks.

 

PS - or, to be fair, perhaps the auditor merely asked in an offhand way, ie just curious/not as if a mandated requirement ?