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Sending "Cooking lessons" in a box. Need compliance help.

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UChef

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Posted 14 September 2015 - 03:08 PM

Hello! I'm a chef and own a start-up called UChef. The service will deliver mini-culinary lessons in a box via mail. Sort of similar to the delivery system of Plated, Blue Apron and Hello Fresh but the business model is more focused on delivering an experience as opposed to a convenience product. You can get a better jist of the venture here if you'd like:  www.charlottemagazine.com/Blogs/Dine-Dish/August-2015/I-Chef-UChef/

 

We will not ship anything perishable, so that eliminates a few Food Code headaches. My main question right now has to do with physical bags. I know I need to get bags approved by the FDA for food storage, but do they need to be sealed-sealed, as opposed to just a zip top bag? Also, I will be using a pick-and-pack logistics warehouse to process these orders. Does this shipment facility need to be a food code approved entity. They will not be portioning food such as flour etc, into the bags them selves. Everything they need to included in the box will come to the warehouse portioned, filled, labeled and sealed.
 
Thank you in advance for any direction. 
 
Mary 


UChef

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Posted 14 September 2015 - 03:09 PM

Also, I reside in North Carolina if that helps with regulations. 



Snookie

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Posted 14 September 2015 - 05:55 PM

FDA does not approve food packaging, but it must be made of approved materials.  How you seal the bags, you determine based on best practices.  It can be a zip lock bag if that is what works best or is most effective or it can be a modified atmosphere packaging.  Generally we use a risk assessment analysis to decide what is required.  You may want the help of a consultant to help you through some of the challenges and questions you have.   


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Snookie

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Posted 14 September 2015 - 05:56 PM

P.S.  Great concept!


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UChef

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Posted 15 September 2015 - 01:18 PM

Thank you! That's one hurdle down I thought was going to be a lot tricker. 

 

Are there any regulations on WHO can ship my packages? I have a pick and pack partner on stand-by but I cant seem to find out if his warehouse needs to be approved. He will not be portioning the bags of ingredients. The bags will come to him portioned and filled. He was just be folding the boxes, putting the bags in the box, and mailing. 



mgourley

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Posted 15 September 2015 - 01:39 PM

I did a quick search. I don't see any FDA regulations pertaining to WHO can ship your packages.

I'm assuming the filled boxes are going to go USPS/FedEx/UPS? If so, they ship food and ingredients every day.

 

The only concern I would have is making sure your pick and pack partner runs a clean operation, so that your customers do not receive anything in the box other than what is expected to be in the box.

 

Marshall



saucy

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Posted 15 September 2015 - 06:51 PM

I would also be concerned about traceability. There should be records kept of what lot numbers of components went into final finished goods. Finished kits should have lot numbers traceable to next immediate recipient.

 

Or is  the pick-n-pack considered retail? Hmmm. Don't think so because you still own the inventory while in your contracted packer's possession.

 

Anyone have input on this?



herdy

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Posted 16 September 2015 - 02:09 PM

That sounds like a really neat idea!

 

I will honestly say that I am doing that so don't know anything for sure, however, I am putting my reasonings in for some ideas that may help you going forward.

 

I would look into the traceability a little more. For food manufacturers or something like that, you should be able to trace one forward and one back. So, even if you don't put the traceability on the box, if you know which lot numbers of, say, flour for example, were sent to which customers on which day, you should be fine. The way to definitely have your bases covered for this would be to just use a label system and put the lot number on each bag of each ingredient. Of course, that is incredibly time consuming and costly to use all of those labels and I doubt anyone else does that. I work for a company who makes paper products for food packaging. We put the lot numbers on each of the boxes we create which then get sent to the food manufacturers. I believe from there they just keep track of which lot numbers of our products are used with which lots of their products but don't actually record our lot numbers on their finished products. I would assume if we had a recall, they would have to recall all of their lots that could possibly have been manufactured/sold in our containers. Using this assumption, if you knew which lot numbers were used when, you would still be able to have an effective recall without having to put the traceability information for each ingredient on each box. However, I would make sure to record ALL traceability information. So if you were to use Ziploc bags to put the ingredients in, I would make sure to record the lot numbers of the Ziploc bags you used, etc. We record the box lot number, the bag lot number, all of that because if any one of our suppliers were to have a recall, we want to know which boxes of our finished goods could be affected.

 

As for the warehouse and shipping, I would just make sure they have a pest control system in place, a chemical/ hazards system in place, and is a generally clean facility. You don't want to have the bags of ingredients leave your facility in a good condition and come into contact with pests/ rodents/ chemicals/ dust and then be placed and transferred by the consumer onto their kitchen counter. I would do a "mini audit" of their facilities just to ensure that it is safe. And you might think about having a documentation for the truck/trailers that come into and leave your facility to ensure that the doors are either locked or sealed and the trailers are in good condition: no signs of pests, no holes, not too dirty. Just if you are using full trucks to transport between facilities. Obviously, once the food is packaged and being sent to consumers by FedEx or UPS or whomever, you can't really make this rule. I know this may seem like going overboard, but I would rather be safe than sorry. If you do ever do a full audit by a third party, you would probably need to have these systems in place and it's much easier to start out that way than changing things up on your suppliers overnight.

 

Like I said before, I don't have any documentation to show you that you definitely need all of this. So definitely ignore all of it if you think it's too much or determine it is unnecessary. Just throwing out some (very wordy) thoughts :)

 

Good luck!





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