I agree it is not the most clearly worded requirement I have ever read in a certified standard, but in general what they are talking about is risk assessment.
When it comes to the design of a new product, including packing, what you don't want to do is go through all the stages of development and design without building in an assessment of risk at each stage. In other words, you don't want to assess the risk only when the product is being produced and shipped to the customer - it should be built into the design stage.
When I was designing a new packing container, I would produce what I called a 'Pre-specification'. This resembled the final product specification as produced and supplied to the customer but it was intended to gather and pin-down all the elements of the product before development work commenced. In this I included an assessment of food safety risk e.g. materials to be used, migration specifications, integrity, tamper evidence in additional to performance and physical requirements. At each stage of development a review of the product under development would be conducted by the team and risk would be included in this review.
So, you should document the procedure for developing new products and ensure safety and risk are clearly addressed in terms of specification and review which should be recorded. If you refer to this link on the Safefood 360 forum you will find a template for such specification or pre-specification which you may be able to adapt.
http://www.ifsqn.com...ntrol-workbook/
I hope this helps.
George
