5 replies to this topic

[Packaging QA]

I've been given generic VACCP questionnaires to complete by a customer of ours, a European Dairy food product manufacturer. They want one completed for every raw material supplied, they state their BRC accreditation requires it.  I've read up on it, and I understand it applies as a HACCP analog to assess risk of adulteration or substitution to food ingredients supplied . So far so good.

 

The twist is, we dont supply them with Food ingredients, we supply primary plastic film packaging only. Am I correct in my understanding that therefore the BRC v7 Food requirements don't apply to our supplied product, and they are overzealous? 

 

 

[alextea]

Hi , 

 

BRC 3.5.1 states:

 

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).

 

So I believe you would be required to complete the questionnaire. Although 5.4.2 doesn't specifically mention packaging, I think that their questionnaire would be required to allow them to risk assess you as a packaging supplier.

 

Hope that helps, 

 

 

[Charles.C]

I've been given generic VACCP questionnaires to complete by a customer of ours, a European Dairy food product manufacturer. They want one completed for every raw material supplied, they state their BRC accreditation requires it.  I've read up on it, and I understand it applies as a HACCP analog to assess risk of adulteration or substitution to food ingredients supplied . So far so good.

 

The twist is, we dont supply them with Food ingredients, we supply primary plastic film packaging only. Am I correct in my understanding that therefore the BRC v7 Food requirements don't apply to our supplied product, and they are overzealous? 

 

Hi Packaging QA,

 

You are correct.

 

BRC7 Food afaik does not require a VA for Packaging. There was a long, long discussion over this on this Forum in 2016-2017.

Ultimately BRC issued a clarification confirming non-requirement which is posted somewhere here.

 

Afaik the situation is unchanged since then but BRC7 users are welcome to correct me if otherwise.

[Packaging QA]

Thanks all for the responses.

 

Seems ambiguously worded in the standard, in that 5.4.2 negates that which is mandated in 3.5.1. However I found that clarification issued by BRC newsletter you mentioned Charles, and it seems their intention is as you say - not required.

[Karenconstable]

Hi Packaging QA,

 

this won't be the last time you are asked this question so even if you don't need it for BRC this time, it is worth having some information about food fraud and plastic packaging on hand.

 

There have been food fraud risks identified in primary (food contact) plastic films, as follows:

 

- False declarations about colourants (the specification says the masterbatch is an FDA (or EU) approved colour when it actually isn't)

- False declarations about 'food grade' status of resins or finished film

- Undeclared (or unexpected) additives that are toxic (for example http://pubs.acs.org/...stlett.6b00435)

 

If you can show your customers that you have systems in place to prevent these things from affecting your products then that will satisfy their GFSI requirements to ensure they purchase authentic, safe packaging materials. 

 

Cheers

[Danica]

Hi,

 

The new version of our packaging standards requirements (IFS PacSecure vs1.1; section 4.20) requires that we have a vulnerability assessment and mitigation plan for product fraud, including raw materials (raw materials, additives, inks, adhesives, solvent, wrapping, material reworks), product formula/configuration, processes (including outsourced), packaging and labeling.

 

It is not a major NC but we still have to do it as part of the IFS PacSecure audit requirements. I assume it will be coming your way soon, vs1.1 of our standard becomes LIVE in June).

 

Best of luck :)

Danica