12 replies to this topic

[labelsuk]

Hello, this is my first post so please be patient!

We have an audit coming up next year to hopefully attain BRC IoP Category 3

We are wet glue label printer (labels used for any product in plastic/glass jars or metal cans), but i am having muchos problemos with regards to section 1, point 1.10:

"The company shall have a system in place to ensure that it is kept informed of relevant product safety issues pertinent to this category, legislative requirements, scientific and technical developments, and industry codes of practice applicable in the country of production and, where known, the country where the product will be sold and/or ultimately used"

Now all of the products we produce for are sold in the uk or ireland, so not much problem there, but as it goes for a printer, it is not up to us what goes on the labels we print, as we dont design them or alter them in any way. It is surely up to the customer to check for legality issues no?

We subscribe to Print Monthly/Weekly which has all new scientific info, but is this enough

I am truely struggling

Thanks

Pete

[Foodworker]

You are correct, it is up to your customer to check that the print design itself is legal, except if you knowingly participate in a fraudulant design eg copying a Heinz beans label for a back street food importer!

The intention of this clause is to ensure that the materials and processes that you use are legal and that you are aware of any significant developments related to your products. In reality, for Category 3 type products, there is very little relevant legislation to worry about.

The scientific and technical development bit may be more applicable, although again most of these relate to food contact issues. An example of where this can apply is in the various panics over benzophenones in inks and varnishes.

Unfortunately to satisfy the clause (it is in Section 1 so you can't justify an exemption) you need a system. It does not need to be complex, but there are two parts to such a sysyem.

1. There needs to be a source of information. This could be a consultant, trade association (member of BPIF?) or the use of recognised websites
2. A process where somebody in your company evaluates the information from whatever source you use to see if anything is relevant.

It is not sufficient to say to the auditor that you look at websites, you need to be able to prove it. The simplest solution is to subscribe to a few websites who provide bulletins eg FSA, Food Quality News, or even IFSQN! and file articles that are relevant to you. Discussion of these in your management reviews will also help you with Clause 1.8.

For Category 3 this should satisfy the auditor.

The BRC Food Standard has a virtually identical clause and the Interpretation Guidelines state that a regular review of websites is acceptable, so it should be the same for the Packaging Standard

[labelsuk]

Thank you very much!! Very Helpful!

Pete

[Foodworker]

Just a quick thought about your initial post and the selection of Category 3 for the risk level.

Obviously I don't know your customers and the types of products that your labels are used on, but wet glue labels are sometimes used in areas where there is open food present. Some coffee filling lines for example are very small and the labeller is close to the filler, especially on manual filling operations.

This may mean that the labels come under Category 2, not 3.

Products which are heat processed and hermetically sealed such as canned food or jams will clearly be Category 3, but it is worth looking at all your customers just to be sure.

[labelsuk]

Although we do produce most of our labels for either food or drink products, these are always applied after the product has been hermetically sealed, and the distance between the filling and labeling stage is always substantial to allow for stock to build up if the labeller stops working on the line.

So although the product is being labeled on the same line as it is packed, there is substantial distance between the labels and any food/drink product.

All of our customers have different halls for the labelling stage and packing stage of the process. Looking through the Packaging Category Examples on page 112 of the Standard i still believe that this puts us in category 3.

Any thoughts?

[Foodworker]

You are probably right, it is just that all of the label printers that I have audited or done consultancy have been CAT 2.

One of the problems with your industry is that you generally have a large number of customers and being familiar with their operations is not easy.

In one label printer that I worked with we developed a checklist to be used when agreeing the requirements for new jobs with customers. This included, amongst other things, questions that enabled the Category to be confirmed each time.

[GMO]

One way to satisfy this at least in part is to sign up to the FSA and FDA alert systems so you're informed if there is a product recall. Although I agree it's unlikely to happen with your products, it shows willing.



Perhaps we could brainstorm ideas on how such a product could cause a food recall?

Despite the onus being on the customer, you would expect packaging to arrive as described no? Well I've had the wrong packaging arrive (ie lamb ready meal packaging in a chicken ready meal packaging box) and not be noticed by the line as only some of it was wrong. Therefore assuming you do preprinted labels that could be something you communicate with your teams when (inevitably) the packaging mix up recalls occur.

Erm, the label could fall off? Ok now I'm struggling...

Edited by GMO, 07 January 2011 - 02:15 PM.

[Foodworker]

There are very few ways that packaging problems can kill or seriously harm people and there was an interesting thread about packaging hazard analysis just before Christmas.

Nearly all potentially fatal risks in my experience involve printing.

Mixed products is my favourite. When I have done Hazard Analysis training in label printers, I pass round a couple of lengths of self adhesive labels which have been printed for pharmaceutical products. I swop one label of each on to the other (before the session obviously) and ask the group to tell me what is wrong with the labels. Nine times out of ten nobody spots the mixed label and they make comment on the design, the print quality etc. I then point out that if somebody takes a digoxin (or whatever the label was) tablet beleiving it to be something else they may die.

In most of the printing operations that I have been in, the possibility of mixed products occurs.

Another one is the presence and legability of print. If you can't read an allegen warning because it has been missed off or is too blurred a sufferer may inadvertantly consume the product. If you have a spot of ink between a couple of numbers it can look like a decimal point and an incorrect dosage may be consumed.

Labels falling off is quite common particularly if the wrong adhesive is used for the individual application eg freezer grade.

I have seen all of the above occur in real life and there are probably loads more.

Edited by Foodworker, 07 January 2011 - 02:43 PM.

[labelsuk]

I suppose the quality of print could be the only issue really, but this is covered in product specifications surely?

Foodworker - i appreciate where you are coming from, but what you are talking about is category 1 product, a packet of paracetamol is not a tin of baked beans!

With regards to the label falling off, we are wet glue label printers so our product is paper, and the customer buys the glue and applies it themselves, we dont get involved in the applying process.

Also i understand the idea of swapping labels around on a self adhesives strip, but in all reality this is never going to happen, if you were printing either flexo or lithographic, as you can swap a plate for one impression then change it back again.

GMO - i have now signed up to the FSA and Food Quality News (where i will be getting specifc news and updates weekly), and i will be reviewing, signing and storing in a folder for 12 months, to be reviewed annually, or distribute and train where neccesary (obviously with whole bunch of new procedures), does that sound about right?

[Foodworker]

My examples were really to elaborate upon GMO's request to brainstorm potential recall situations and were general in nature.

Print quality should be defined in the specification, but it is the printer's responsibility to make sure that the print is correct and legible. In the forthcoming Issue 4 of the Standard it looks as though this aspect will have its own individual section.

Just to clarify a point though, the BRC risk category determination is based upon the direct contact or otherwise with a high risk product, be it food, toiletries or even pharmaceuticals. Labels for a paracetamol could still be Category 3.

You are right that mixing of labels on a strip is unlikely during normal production as the plates are changed followed by a make ready period. It can occur in some circumstances - eg digital label printers where very short runs can be the norm. Another process where I have seen it is after printing, where self adhesive labels go through a rewinder or other sorting operation with defective labels being replaced from good stock.

With wet glue labels the likelihood of labels coming off is as you say normally the fault of the packer not the printer. The only time I have come across anything like this being blamed on the printer was when the sheet was printed the wrong way round (I can't remember if it was machine or cross direction).

Edited by Foodworker, 07 January 2011 - 04:17 PM.

[GMO]

Building on that, I've had layers of print missing and incorrect inks (meaning the print rubs off) before. Depending on what's missing that could be an issue; e.g. miss off the allergy info!

[kaz]

One thing to bear in mind is that BRC/IoP is under review. Publication of issue 4 at the moment estimated February 2011. The draft version has a section 5.2Packaging Print Control

[BBrandDesign]

You are correct, it is up to your customer to check that the print design itself is legal, except if you knowingly participate in a fraudulant design eg copying a Heinz beans label for a back street food importer!

The intention of this clause is to ensure that the materials and processes that you use are legal and that you are aware of any significant developments related to your products. In reality, for Category 3 type products, there is very little relevant legislation to worry about.

The scientific and technical development bit may be more applicable, although again most of these relate to food contact issues. An example of where this can apply is in the various panics over benzophenones in inks and varnishes.

Unfortunately to satisfy the clause (it is in Section 1 so you can't justify an exemption) you need a system. It does not need to be complex, but there are two parts to such a sysyem.

1. There needs to be a source of information. This could be a consultant, trade association (member of BPIF?) or the use of recognised websites
2. A process where somebody in your company evaluates the information from whatever source you use to see if anything is relevant.

It is not sufficient to say to the auditor that you look at websites, you need to be able to prove it. The simplest solution is to subscribe to a few websites who provide bulletins eg FSA, Food Quality News, or even IFSQN! and file articles that are relevant to you. Discussion of these in your management reviews will also help you with Clause 1.8.

For Category 3 this should satisfy the auditor.

The BRC Food Standard has a virtually identical clause and the Interpretation Guidelines state that a regular review of websites is acceptable, so it should be the same for the Packaging Standard

Foodworker Thank you so much for the information you provided here. This is the exact one for which I was looking here. It is surely up to the customer to check the design for legality issues.