11 replies to this topic

[Simon]

Thanks to the BRC/IOP Packaging Standard packaging materials in the UK are good enough to eat; even secondary and tertiary packaging is completely contaminant free. I've no doubt there are food producers all over the world with hygiene standards nowhere near the level found in your average UK cardboard box manufacturer. UK packaging is undoubtedly the safest in the world.

I have a friend who has recently returned from the USA; he spent a few weeks at a manufacturer of direct contact food packaging who supply large US retailers. Guess what - they have no hygiene standards. No hairnets, no hand-washing, no pest control, no glass control, no blade control, nothing, nada, zip.

Are the Brits anally retentive hygiene freaks or are the Yanks a public hygiene risk?

Who has got it right?

Regards,
Simon

[Franco]

Who has got it right?

The one with the most cost-effective food safety system.

Maybe both, depends on their food safety goals

[Simon]

The one with the most cost-effective food safety system.
Maybe both, depends on their food safety goals

Hi Franco,

I get your point Franco; both companies are doing what they need to do to operate in their respective markets and chemically speaking food contact packaging is safe for use with foods through tight legislation on both sides of the pond.

The difference is everything else and I don't think it's just about cost-effectiveness or food safety goals; it's about whether the packaging is safe and fit for purpose.

If my friends experience is typical of US packaging companies is the risk to the consumer from the lack of having all of the hygiene systems just a perceived one? If there was a real risk then surely there would have been death and injury to US consumers, which surely would have brought pressure on US packaging companies to have all of the systems ‘a la' BRC/IOP.

It's all about minimisation of risk and maybe we have gone too far in the UK? Have we determined the risk incorrectly?

Personally I believe hygiene and a clean as you go philosophy helps create a good workplace environment for productivity and efficiency, but that's not the point.

I'd love to hear a US perspective on what the large retailers demand and expect from their packaging suppliers.

Regards,
Simon

[Franco]

I'd love to hear a US perspective on what the large retailers demand and expect from their packaging suppliers.

Me too.

And from Italian companies too

[Charles.C]

Dear Simon,

It's an old thread but I only just noticed it. Although packaging BRC is not really my line, I wondered whether a very large square factory I encountered making non-food contact material only (with ISO9k2k approval) would generate a critical defect for the reason of only having 3 solid fixed walls and 1 open mesh wall (to enable ventilation) ? Regardless, it was extremely clean (no birds ) but a first in my experience. (Ranking just below the 'company' processing frozen seafood using a fully open plate freezer mounted on the beach in front of their house).

Rgds / Charles.C

[Simon]

Dear Simon,

It's an old thread but I only just noticed it. Although packaging BRC is not really my line, I wondered whether a very large square factory I encountered making non-food contact material only (with ISO9k2k approval) would generate a critical defect for the reason of only having 3 solid fixed walls and 1 open mesh wall (to enable ventilation) ? Regardless, it was extremely clean (no birds ) but a first in my experience. (Ranking just below the "company" processing frozen seafood using a fully open plate freezer mounted on the beach in front of their house).

Rgds / Charles.C

Never heard or seen a factory like that. BRC Packaging standard has two levels (and four sides); I don't think the factory you encountered would pass, birds or no birds.

Simon

[Charles.C]

Dear Simon,

Thanks for giving an opinion. I instinctively agreed with you on the basis that the packaging produced was clearly at 'significant unspecified risk' due to the direct and gross external exposure. My particular worry was that this risk might eventually pass over to the food content in the event of breakage of the direct-contact food packaging (I assume such risk is usually ignored in the BRC/P non-contact version, although the event can occur in my own experiences).
On a mini scale, it is not so rare to see multiple large extractor fans (backed by rear screening) mounted on factory walls and these generally pass without comment . The non-direct contact aspect was the general logic invoked by the company when I queried conformance to requirements for things like infrastructure in ISO9k.
I was unable to see any specific BRC regulation (in the food version) being non-conformed, there is no mention of 4 (anything) walls.
Conclusion - innocent till proven guilty. But not for me.
How about ISO22k ?

Rgds / Charles.C

[Simon]

Thanks for giving an opinion. I instinctively agreed with you on the basis that the packaging produced was clearly at "significant unspecified risk" due to the direct and gross external exposure. My particular worry was that this risk might eventually pass over to the food content in the event of breakage of the direct-contact food packaging (I assume such risk is usually ignored in the BRC/P non-contact version, although the event can occur in my own experiences).

I think it does Charles, requirements for secondary packaging assume that primary packaging is doing its job, but I do see your point.

On a mini scale, it is not so rare to see multiple large extractor fans (backed by rear screening) mounted on factory walls and these generally pass without comment . The non-direct contact aspect was the general logic invoked by the company when I queried conformance to requirements for things like infrastructure in ISO9k. I was unable to see any specific BRC regulation (in the food version) being non-conformed, there is no mention of 4 (anything) walls.
Conclusion - innocent till proven guilty. But not for me.
How about ISO22k ?

I think BRC assumes four walls and a roof are in place. In the packaging standard under 5.3 Building Fabric it requires it to be well maintained, accessible, sound, cleanable etc. It does mention sufficent ventilation should be provided, so maybe that means a wall of fans or maybe even a missing wall is acceptable. However, in pest control the building must be suitable proofed against the entry of all pests.

Simon

[Charles.C]

Dear Simon,

Well maintained - generally yes; accessible, had screened doors (!) so - yes; sound - well, there weren't any visible holes due to breakage so - yes; cleaning - well, it looked clean, they claimed manual + pneumatic and had a procedure so - qualified yes.

Pests - Ah! I forgot to mention that the facility also had a large sliding section which could be used to fully enclose the unit in non-operational periods (worried about burglars or strong toothed night rats maybe). This addition was seemingly sufficient leverage to enable satisfactory, independent pest control documents to be readily available. Situation certainly wasn't proof against small flies, mosquitoes etc when running although electrocuter data were exemplary (perhaps slightly suspicious but …). 'Suitably proofed', a nice unspecific term for the auditor, they have my sympathy in interpreting that, or is it an advantage ?
I deduce from yr comments that building-wise, BRC does not textually differ that much for direct/non-direct scenarios in which case it comes down to interpretative, ie people are deciding to make allowances. There are some precedents in variations of defect ratings of potential contamination risks for food establishments depending on likelihood or not of immediate food contact. These are frequently not specified but are nonetheless 'understood'.

Regardless, pests is the nearest opportunity for failure I have seen so far.

Rgds / Charles.C

[Simon]

"Suitably proofed", a nice unspecific term for the auditor, they have my sympathy in interpreting that, or is it an advantage ?

Even prescriptive standards such as BRC Packaging have to be somewhat generic to be applicable to the whole industry.

The facility you mention earlier Charles, which country? I'm just relating back to the topic title e.g. comparing UK and USA standards (and other countries).


Regards,

Simon

[Charles.C]

Dear Simon,

It was near CharlesChew but surely not on his regular list (must admit didn't notice the full thread caption). Actually the 'open air' style reminded me of a tour round the fish filleting tables of Grimsby a few years back.

Rgds / Charles.C

[Simon]

It was near CharlesChew but surely not on his regular list (must admit didn't notice the full thread caption). Actually the "open air" style reminded me of a tour round the fish filleting tables of Grimsby a few years back.

Mmm! Grimsby, I can smell it now.