13 replies to this topic

[Fishlady]

We use wax coated boxes for packing fresh fish, and these boxes must be assembled using staples.  The boxes are assembled (including adding absorbent pad and plastic liner) in a loft above the production floor and then sent down to the production area on a metal chute.  We are working toward BRC certification and are trying to determine how to set up a monitoring system to show that we are preventing metal contamination.  Although we have never had a complaint of staples in the product, obviously that alone is not going to satisfy an auditor. Does anyone have an idea for a practical monitoring system?  And how would you validate that such system is working properly?

[redfox]

Hello Fishlady,

 

If using staple can not be avoided in assembling you packaging, you must have a risk assessment to show to the auditor that metal from staple can't contaminate your product. You can also have a check point to ensure no staple is lost that may contaminate your product until it leave on your facility. Your metal control must be robust and record must always be available during audit either IA or third party audit.

 

regards,

redfox

[Charles.C]

Hi fishlady,

 

We use wax coated boxes for packing fresh fish, and these boxes must be assembled using staples

 

May i ask why ? IMEX this is an atypical procedure for a seafood packing operation.

 

IMO, it surely is a potential hazard.

[Fishlady]

Wetlock boxes are usually designed to be assembled by the user, held together with staples.  We are looking to see if there is another style that does not use staples, but these are going to be more expensive- maybe more than our customers may be willing to pay for.

[Scampi]

anything is cheaper than a recall............

[Fishlady]

Hello Fishlady,

 

In my previous post...it should be "If the staple can not be avoided...."

 

regards,

redfox

Do you have specific advice for how to set up the checkpoint?  That is where I am looking for a practical solution. 

[seafood]

Good to see another seafood company here.  There are fold-able wax coated boxes that do not use staples but they are a bit more expensive.  If you think about the cost per lb of product it normally does not end up being too much more.  Do as others have said and create a risk assessment for this particular foreign material hazard.  You could write a SOP that outlines the only area appropriate for creating boxes is the loft and make sure the area is secured enough that there is not a way that a loose staple could get out of the area. Your operational sanitation checks should encompass foreign material monitoring especially in this area.  If there are staples all over the ground there maybe additional controls that need to be implemented. Using customer complaints is only one part of validating your control of this hazard but you must have a good customer complaints system where all complaints are trended according to the type of non-conformity.  Also ensure all of your staff has been trained in foreign material hazards, employees in the boxing area must be fully aware of the hazards as it relates to their job function.  You should do a thorough inspection of the box-making area during your foreign materials internal audit.  As for monitoring, that may be a bit tougher, you could sample/inspect a representative number of boxes per hour written in a SOP and only document when there is an occurrence/corrective action or document how many are actually checked.  These items should be getting a line inspection regardless but documenting it actually shows you are doing it. 

[Fishlady]

Good to see another seafood company here.  There are fold-able wax coated boxes that do not use staples but they are a bit more expensive.  If you think about the cost per lb of product it normally does not end up being too much more.  Do as others have said and create a risk assessment for this particular foreign material hazard.  You could write a SOP that outlines the only area appropriate for creating boxes is the loft and make sure the area is secured enough that there is not a way that a loose staple could get out of the area. Your operational sanitation checks should encompass foreign material monitoring especially in this area.  If there are staples all over the ground there maybe additional controls that need to be implemented. Using customer complaints is only one part of validating your control of this hazard but you must have a good customer complaints system where all complaints are trended according to the type of non-conformity.  Also ensure all of your staff has been trained in foreign material hazards, employees in the boxing area must be fully aware of the hazards as it relates to their job function.  You should do a thorough inspection of the box-making area during your foreign materials internal audit.  As for monitoring, that may be a bit tougher, you could sample/inspect a representative number of boxes per hour written in a SOP and only document when there is an occurrence/corrective action or document how many are actually checked.  These items should be getting a line inspection regardless but documenting it actually shows you are doing it. 

Thank you!  This is the kind of advice I was looking for.

[Charles.C]

Hi Fishlady,

 

Based on these seafood container specs, you may be facing  a difficult situation from an audit POV -

 

http://www.styropack.co.uk/fishboxes/

http://www.plastpac.com/fish.html

 

Nonetheless if the practice you describe is "standard" in yr local fishing area for yr particular application, it may be arguable as a "best practice".

 

I'm curious as to whether this is a particular USA-oriented practice as I have audited many (on-shore) seafood factories outside USA  and never encountered this packaging style.

 

Will be interesting to assess the severity associated with an occurrence of this foreign object in the finished product.

[Fishlady]

Hi Fishlady,

 

Based on these seafood container specs, you may be facing  a difficult situation from an audit POV -

 

http://www.styropack.co.uk/fishboxes/

http://www.plastpac.com/fish.html

 

Nonetheless if the practice you describe is "standard" in yr local fishing area for yr particular application, it may be arguable as a "best practice".

 

I'm curious as to whether this is a particular USA-oriented practice as I have audited many (on-shore) seafood factories outside USA  and never encountered this packaging style.

 

Will be interesting to assess the severity associated with an occurrence of this foreign object in the finished product.

Thank you, Charles.  Stapled wetlock cartons have been standard on the West Coast and Alaska for as long as I have been in the business; they are less expensive and seen as "greener" than Styrofoam.  State and federal food authorities have not objected to the practice during any audits I have been involved in.  But the BRC standard appears to be stricter. 

[Charles.C]

Hi Fishlady,

 

Thks yr response. apologies that I missed the “fresh” fish in yr OP which explains a lot as my experience has been primarily with non-fresh. Different worlds.

 

I deduce yr containers are something like the variety of options in  this link –

 

http://www.skipsmarine.net/wax1.htm

 

Within the GFSI-recognized FS Standards, BRC is possibly the most highly fixated on avoiding metallic contamination in end products.

 

Nonetheless, if other operators in yr area are using similar stapled packaging and have successfully obtained BRC certification, a (“internal”) precedent may likely exist within the local auditing bodies.

 

From a risk assessment POV, I anticipate the severity will be M to H depending on yr criteria (this is subjective). If you can justify likelihood of occurrence (L) in end-product is Low to negligible, the overall risk can be non-significant via risk matrix or risk Table, ie no CCP. The justification for L could come from customer complaints/industry usage experience but, as discussed in the nice post 7, will likely require some own monitoring data also, eg from a designated “pilot” study. The frequency of monitoring theoretically relates to detection statistics such as those for Salmonella which can get rather substantial.  Or you could use an ad-hoc method, eg 1-5% of daily (=lot) production. Either way may unfortunately be expensive if the testing is box-destructive (is it?)

 

This situation  is somewhat analogous IMEX to factories unwilling to invest in metal detectors (MDs) so that they are then obliged to implement “justification” procedures  in preparation for audit arguments revolving around the fact that all the other, similar, operators in area have  already installed MDs. (the non-MD options are discussed in some detail in the well-known FDA text on Fishery hazards,2012 which I’m sure you are familiar with).

 

(Another poster here (trubertq) is, I think, sometimes quite involved with BRC/fresh seafood and might offer some useful comments but not sure if around at moment.)

[SQFconsultant]

That was an excellent response - seafood.

 

We have a number of clients in the seafood industry and this type of box is typical - but times they are changing, albeit slowly to boxes sans staples. We did a cost analysis based on the metal/contamination risk and the associated paperwork and labor time that would be involved and found that it cost a lot less to switch to non-staple boxes boxes in the long run without impact to the customers for a large client of ours, in fact there were cost savings that increased profits.

[foodsafetyAUS]

Hi all,

 

We are a packing shed that packs oranges in the box. We have to use pallet staples. Is there anyway that we can control the staples in the production? Do you have any form that can help me? I have completed a risk assessment and the risk assessment result was no significant so the only control measure that I can see is developing a form that is practical for the production. any input much appriciated. 

 

Kind regards

[Charles.C]

Hi all,

 

We are a packing shed that packs oranges in the box. We have to use pallet staples. Is there anyway that we can control the staples in the production? Do you have any form that can help me? I have completed a risk assessment and the risk assessment result was no significant so the only control measure that I can see is developing a form that is practical for the production. any input much appriciated. 

 

Kind regards

 

Standard ??? It can matter.

 

generically, If the practice you refer is accepted as best practice in yr industry this may "smooth" auditorial tolerances.

 

How did you decide that the risk was insignificant ? Typical approach is similar to Post 11 combined with a risk matrix.