5.4.2 Vulnerability Assessment for Apple packhouse

I am struggling with this.  We pack apples into cardboard cartons for export.  The apples are grown on our orchard, grown and picked by us and then packed and transported to exporter by us.  

We have a very robust traceability system as is required for our biosecurity status.

We buy in packaging (cartons, trays) which are preprinted with our exporters requirements.  The only raw food material we have is the apple themselves which are grown here.

I see Clause 5.4 states "fraudulent or adulterated food raw materials"  However Clause 5.4.2 states "A documented VA shall be carried out on all raw food materials or groups of raw materials

So only food products are required to be covered by this V.Assessment?  Or our cardboard packaging as well? 

Help.....

Thanks

Louise

New Zealand

Dear Louise:

I think in your case  the V assessment will be applied for the apples only as it is the only food ingredient and the Cartoon boxes not food ingredient .

if you are the supplier of the apples , have no history for fraud as well as the apple fruits it self has no history of fraud also you can use the attached form to cover the raw material V assessment .

Best Wishes

Ahmed

Hi Louise

Do the packaging as well.

Just been through a recent audit with a client who 'grows chickens' this is the only raw material and then packs them in bags and boxes.

We did the vulnerability assessment on the feathered ingredient.

We got a 'slap' from the auditor because we had not considered the risks involved in the packaging.

rgds