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#1 fgjuadi

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Posted 11 November 2014 - 08:21 PM

Hi

 

R&D  wants to introduce a new product without tamper proof packaging. 

 

I let them know I think this is a bad idea, but is there a law/standard (FDA, SQF, BRC, AIB, ISO/FSSC) that I can refer to ?  I don't have anything to support my evidence, and I was like, well, I'm sure one of the standards will have a clause about that, but I can't find a single one which requires packaging itself be tamper proof.

 

In the mean time,. I'm using the "tampering is a real risk and our HACCP team has identified the risk and determined that the only way to control it is with tamper proof packaging", which  is flying as well as a dead fish.  They want someone "official" to tell them...

 

Thanks


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#2 Snookie

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Posted 11 November 2014 - 10:14 PM

This might be a good place to start.

 

http://www.ag.ndsu.e...kaging-labeling

 

Regulations aside......it would be a huge liability risk.  It opens the door for your product to be tampered with and then a lawsuit when a consumer is hurt or claims to be hurt.  It's like putting all of your money and valuables in the living room with all of the lights on and leaving the door open....it just begs for trouble. 


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#3 Mike Green

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Posted 11 November 2014 - 10:15 PM

Hi

 

R&D  wants to introduce a new product without tamper proof packaging. 

 

I let them know I think this is a bad idea, but is there a law/standard (FDA, SQF, BRC, AIB, ISO/FSSC) that I can refer to ?  I don't have anything to support my evidence, and I was like, well, I'm sure one of the standards will have a clause about that, but I can't find a single one which requires packaging itself be tamper proof.

 

In the mean time,. I'm using the "tampering is a real risk and our HACCP team has identified the risk and determined that the only way to control it is with tamper proof packaging", which  is flying as well as a dead fish.  They want someone "official" to tell them...

 

Thanks

Interesting one!

 

It sounds like its time for TACCP & VACCP plans to go alongside your HACCP and QACCP! 

 

I thought I had a bit of evidence for you- PAS 96 (2010) in the UK did make reference to the use of tamper-evident packaging-but when I looked at the 2014 version Attached File  PAS 96 (2014).pdf   17.96MB   29 downloads

 

...it is no longer there-(not sure why it dissapeared!)

 

I think in terms of the US-there seems to be quite a lot of speculation around whether the final version of FSMA will align food with OTC drugs and introduce a tamper evident packaging requirement -but I gues the jury is still out on that one!

 

Mike


I may sound like a complete idiot...but actually there are a couple of bits missing

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#4 cazyncymru

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Posted 11 November 2014 - 11:18 PM

I've already done my TACCP / VACCP. Surprising how many technical people have not heard of them ! ( or should that be frightening!)


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#5 Snookie

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Posted 12 November 2014 - 12:46 AM

Hi

 

hey want someone "official" to tell them...

 

Thanks

 

 

Have someone call Johnson & Johnson and have them ask how that worked for Tylenol and the 7 people who died due to tampering.


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#6 fgjuadi

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Posted 12 November 2014 - 03:16 PM

Well, the problem isn't lack of risk assessments or examples.  The problem is that they don't agree it's a risk / "We don't have to do it to pass the audit" / "It's not illegal to sell it like that" .  The product is in boxes and tins, shipped to the customer (hotels/cruise ships/weddings).  I was like, "But what if it's a cruise ship with a bunch of ISIS members" which failed to impress them. 

 

I think in the end they'll come around (because I won't approve the new product until they do) , but I don't want it to turn into a power/office politics battle.  


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#7 Snookie

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Posted 12 November 2014 - 11:44 PM

Well, the problem isn't lack of risk assessments or examples.  The problem is that they don't agree it's a risk / "We don't have to do it to pass the audit" / "It's not illegal to sell it like that" .  The product is in boxes and tins, shipped to the customer (hotels/cruise ships/weddings).  I was like, "But what if it's a cruise ship with a bunch of ISIS members" which failed to impress them. 

 

I think in the end they'll come around (because I won't approve the new product until they do) , but I don't want it to turn into a power/office politics battle.  

 

Yep that's the hard part getting it done without it being a battle. 


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#8 Cathy

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Posted 13 November 2014 - 01:06 PM

This comes down to some management commitment !  Good lick to you.  Sharing stories helps (like the Tylenol one).  Also, I wanted to state that in my opinion, food defense does not belong within the HACCP Plan.  HACCP is intended for hazards reasonably likely to occur, does it not?  


Cathy Crawford, HACCP Consulting Group
http://haccpcg.com/

#9 tj7933

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Posted 13 November 2014 - 02:22 PM

Hi,

 

Correct me if I am wrong, but does your facility not require a food defense program. 

 

For the companies that I work with that export to the US, this is a requirement, and one of the components of a food defense program is to ensure that  "Finished product is adequately protected against intentional or unintentional contamination and deterioration prior to shipping."

 

If your facility is considering exporting to Canada...

 

I do know that this is one of the requirements of FSEP.

 

``B.2.1.4

 

All food safety specifications or requirements of the finished product have been met prior

 

to shipping to retail/the customer. (e.g., temperature, certificate of analysis)

 

Finished product is adequately protected against intentional or unintentional

contamination and deterioration prior to shipping.``

 

Otherwise.. I agree with everyone else, it is surprising that they would be willing to take this risk with all the significant examples of what can go wrong if tamper evident packaging is not being used.






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