7 replies to this topic

[Simon]

Page 6 of the BRC/IOP Packaging Standard, a few paragraphs.

Any comments?

Regards,
Simon

[Edwina Chicken Currie]

Please also see Page 54, Appendix 1: Fields of Evaluation, point a)

How many companies manufacturing 'ancillary items' such as labels, closures, dispensing mechanisms, strapping, and pallets, hold BRC/IoP certification??

Further, if used in conjunction with the decision tree on page 45, following the route where the item may enter an area where there may be open product, and the item has potential to contaminate, how many 'ancillary items' suppliers will hold certification for Category B materials??????????

[Charles Chew]

Risk evaluations in packaging materials is generally focused on chemical issues like toxic migrations etc rather than the other category of hazards. Having said this, I assume that GHP is being effectively implemented and strictly followed. Facilities that manufacture labels and strappings are low risk. Closures and dispensing machines require further evaluations.

There is often this danger of being over reactive to hazards that are in reality already under control through effective SOPs.

If you refer to the hazard analysis for FOOD as in jam production, we are seriously looking at only 3 CCPs.

Product characteristics is therefore an important issue.

Charles Chew

[Simon]

Excellent points Fiona. It is difficult…imagine being a supplier of pallet strapping with maybe 1% of your production output being used in a food environment. This supplier cannot be expected to be up to speed with the BRC/IOP and if you asked him to achieve it he would probably laugh (or cry).

It is the responsibility of the retailers and the food producers to educate suppliers and to ensure that relevant suppliers achieve the BRC/IOP Standard. Maybe it is an opportunity for a specialist strapping company to emerge that provides hygienically produced strapping specifically to meet the needs of the food industry.

On your second point this is the responsibility of the Certification Bodies who should adjudicate. To avoid confusion maybe there could be an official BRC list?

Regards,
Simon

[rheath]

Fiona,

With respect to category A product going into open food environments.

The approach we have taken (as corrugated supplier) is to put the accountability back onto the food producer, as standard we will:

1. Contract review/Enquiry stage determine what our product will be used for
2. Condition of supply is that we are not recognised as a direct contact package supplier / our product cannot be used in customers open area factory.

In practice this has meant that one customer who was insisting that we were category B, made a small modification to their process and we were then OK.

If we were not commercially attractive, the customer may not have been as willing to carry this out.

In my experiences there are very few applications that the outer case needs to be Category B.

Obviously this will change dependent on the type of packaging.

[Edwina Chicken Currie]

:)

Edited by Fiona, 13 June 2004 - 04:07 PM.

[rheath]

Simon,

We tried to source easily identifiable blue plastic strapping - could we find it - afraid not.

This in my mind would be a simple modification in colour additive that would be food industry friendly..

If enough of us were to request it - maybe it could become industry standard!

[Charles Chew]

Fiona,

Agree with you. It is exactly the point that I have been trying to point out. The product sensitivity of the particular industry is essential in determining how far one should go in placing the degree of "procedures" in a program be it BRP/IOP or HACCP for the control of CCPs or effective GMPs, SSOPs or PSOP etc.

Sure, there is a big difference between a facility that makes paper wrap for UHT pack versus another that makes the external label of a product. Essentially, the difference between primary and secondary packaging.

Some of the issues discussed on BRC/IOP in the area of "packaging" frightens the wits out of me. Every industry has different risk levels. Relax.

Charles Chew

Edited by charleschew, 11 June 2004 - 03:44 PM.