This is my first post and just want to say that I refer to this site almost daily which is a testament to what a great resource it is!
I am the HACCP Lead for our organization which manufactures direct food contact labels. We are in the process of preparing for our first BRC Global Packaging certification audit.
The raw material we order to manufacture our labels comes in large rolls with blank labels and food safe adhesive already applied. The labels and adhesive (obviously being the highest risk) are rolled face down so they're not exposed. When the rolls come in they are not unpacked (i.e. plastic packaging is not removed) until they are required to be used for manufacturing the labels and at that time they are taken from storage and unwrapped by the production stagers. When a production job is complete, they return the unused portion of the label roll to the raw materials storage area and the rolls are not repacked in plastic to protect them. While conducting a process flow verification on staging this week, my colleague and I discussed this and he is of the opinion that because the labels and adhesive are not exposed, that when we document our risk assessment that it should show that there is no or little risk to the food contact labels.
I disagree and believe that leaving the rolls uncovered provides vulnerability to contamination by dust, sneezing employees, etc. In addition, s. 5.9 of the Standard seems clear on this.
Would greatly appreciate your opinions on this - especially anyone who is in the food contact label business. Thanks:)