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Is a Vulnerability Assessment Required for a Packaging Manufacturer?


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Technical1000

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Posted 27 November 2015 - 09:40 AM

Hi,

 

I am new to this.
We  are a  food packaging company. We and have received a Supplier Self Assessment Questionnaire. In this we have been asked if we have completed and documented a Vulnerability Assessment on our suppliers of raw material and to detail this. 
I thought that vulnerability assessments were for food suppliers. I can not find anything in the new BRC Standard for Packaging regarding this.
Any help  and advise would be very much appreciated. Many thanks

 

regards,

 

Tracy



Ehab Nassar

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Posted 27 November 2015 - 11:27 AM

Are your packaging in direct contact with food or not .



Technical1000

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Posted 27 November 2015 - 11:32 AM

hi,

 

Thanks for the reply. We are direct food contact

 

regards,

 

Tracy



Ehab Nassar

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Posted 27 November 2015 - 01:37 PM

hi  Tracy ,

 

"The GFSI states that a food fraud vulnerability assessment should include an evaluation at the appropriate points along the supply chain.  They define this as being raw materials, ingredients, products and packaging.  The aim being to identify and prioritize vulnerabilities for food fraud."

So if your customer is following the GFSI you may requested this assessment according to :

ISO/TS 22002-4:2013 Prerequisite programmes on food safety -- Part 4: Food packaging manufacturing and PAS 223

 

 

 



Ehab Nassar

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Posted 27 November 2015 - 02:08 PM

there is also PAS 96 : 2014 "guide to protecting and defending food and packaging from deliberate attack .

you can download it here :

 

http://www.food.gov....ction-guide.pdf

 

it is not only for food defence but included some other criteria like fraud ,protection ,...

 

for more info:

http://www.packaging...g_us_there.pdf 

 

Good luck ,

Ehab



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Charles.C

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Posted 27 November 2015 - 02:14 PM

 

Hi,

 

I am new to this.
We  are a  food packaging company. We and have received a Supplier Self Assessment Questionnaire. In this we have been asked if we have completed and documented a Vulnerability Assessment on our suppliers of raw material and to detail this. 
I thought that vulnerability assessments were for food suppliers. I can not find anything in the new BRC Standard for Packaging regarding this.
Any help  and advise would be very much appreciated. Many thanks

 

regards,

 

Tracy

 

 

Hi Tracy,

 

Welcome to the Forum ! :welcome:

 

May I ask if yr query relates specifically to the BRC Packaging Standard ?

 

GFSI is an organisation which benchmarks Food Standards. Afaik GFSI  do not issue Standards although "GFSI approved" and similar claims seem to nonetheless be in common usage.


Kind Regards,

 

Charles.C


Technical1000

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Posted 27 November 2015 - 05:06 PM

Hi Charles,

 

Yes my query relates specifically to the BRC Packaging Standard to which we are accredited to. I can not find any reference in the new standard to this. Just wondering if I have missed it?

Any help will be very much appreciated.

Note. We produce card board boxes for direct food contact.

 

kind regards,

 

Tracy



Charles.C

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Posted 27 November 2015 - 05:19 PM

Hi Charles,

 

Yes my query relates specifically to the BRC Packaging Standard to which we are accredited to. I can not find any reference in the new standard to this. Just wondering if I have missed it?

Any help will be very much appreciated.

Note. We produce card board boxes for direct food contact.

 

kind regards,

 

Tracy

Hi Tracy,

 

I'm not a Packaging Person myself but offhand, I cannot recall any previous query on VA with respect to BRC Packaging std.

 

I anticipate that you will get some response from users of the Standard in the near future (unless they are all doing Black Friday.....)


Kind Regards,

 

Charles.C


Technical1000

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Posted 27 November 2015 - 05:40 PM

Hi Charles,

 

Thanks for your reply. I would be very grateful if anyone would advise me, about this.  :helpplease:

 

Thanks

 

Tracy 



Charles.C

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Posted 28 November 2015 - 04:25 AM

hi  Tracy ,

 

"The GFSI states that a food fraud vulnerability assessment should include an evaluation at the appropriate points along the supply chain.  They define this as being raw materials, ingredients, products and packaging.  The aim being to identify and prioritize vulnerabilities for food fraud."

So if your customer is following the GFSI you may requested this assessment according to :

ISO/TS 22002-4:2013 Prerequisite programmes on food safety -- Part 4: Food packaging manufacturing and PAS 223

 

 

 

 

Hi Ehab Nassar,

 

Thks yr post.

 

JFI, the current GFSI Guidance Document, ver 6.4 (2015) contains no reference to the words "fraud" or "vulnerability".

 

Afaik, the topic will be included in the 7th edition scheduled for 2016 and be based on the position paper of July 2014 -

 

Attached File  gfsi - Food_Fraud_Position_Paper.pdf   326.95KB   333 downloads


Kind Regards,

 

Charles.C


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Charles.C

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Posted 01 December 2015 - 09:08 AM

Hi Charles,

 

Yes my query relates specifically to the BRC Packaging Standard to which we are accredited to. I can not find any reference in the new standard to this. Just wondering if I have missed it?

Any help will be very much appreciated.

Note. We produce card board boxes for direct food contact.

 

kind regards,

 

Tracy

 

Hi Tracy,

 

I downloaded a copy of the BRC5 Packaging Standard.

 

Like yourself, after scanning I can see no mention of "Vulnerability" or "Fraud" anywhere. Including the Glossary.

 

So unless BRC have invented a "New Word" for Packaging, i daresay they've been too busy with "Food7"  to get around to this Standard. So far.

 

Packaging people are welcome to correct me (us) of course.


Kind Regards,

 

Charles.C


AndyDiff

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Posted 07 December 2015 - 04:22 PM

Hi. There was an update email from BRC clarifying the vulnerability requirement for the BRC Food Standard as some food packing companies have misinterpreted this requirement to include packaging. I have copied the relevant section of the email below.  As you say, this is not part of BRC Packaging.

 

Clarification of Clause 3.5.1.1

 

Analysis of the audit data has highlighted that Clause 3.5.1.1 may be misinterpreted. This clause includes the requirement for sites to ‘take into account the potential for substitution and fraud’ (see Clause 5.4.2). The purpose of this reference is to highlight that supplier approval processes must include consideration of any risks highlighted during the vulnerability assessment, such as those identified when completing activities for Clause 5.4.2.
Clause 5.4.2 clearly states that it is only relevant to food raw materials (it does not cover packaging raw materials, so we do not expect supplier approval processes for packaging materials to include an assessment for substitution or fraud). All other requirements of Clause 3.5.1.1 apply to all raw materials (both food and packaging raw materials).

 

 

Regards

Andrew



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Technical1000

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Posted 07 December 2015 - 04:33 PM

Hi Andrew,

 

Many thanks for your reply and clarifying this for me. Much appreciated !! :smile:  

 

Kind regards,

 

Tracy



Charles.C

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Posted 07 December 2015 - 08:29 PM

Hi Andrew,

 

Many thanks for your reply and clarifying this for me. Much appreciated !! :smile:  

 

Kind regards,

 

Tracy

 

Hi Tracy,

 

It is possible you have misunderstood the previous post.

 

Afai understand the comments refer to BRC7 Food, not  BRC5 Packaging.

 

The post is perhaps sort of in the wrong thread but interesting nonetheless.

 

@Andrew - may i enquire as to the timing and location of the email you refer. Was this a personal communication or ? Does not seem to have been noticed on the IT as yet ? Regardless yr input is appreciated. Thanks.


Kind Regards,

 

Charles.C


AndyDiff

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Posted 08 December 2015 - 09:54 AM

Hi Tracy,

 

It is possible you have misunderstood the previous post.

 

Afai understand the comments refer to BRC7 Food, not  BRC5 Packaging.

 

The post is perhaps sort of in the wrong thread but interesting nonetheless.

 

@Andrew - may i enquire as to the timing and location of the email you refer. Was this a personal communication or ? Does not seem to have been noticed on the IT as yet ? Regardless yr input is appreciated. Thanks.

 

Hi Charles

 

I suppose this item overlaps in both threads in that the original question was asking if the new BRC Packaging 5 Standard requires a vulnerability assessment, which it does not, but then the reason some packaging suppliers are being asked to complete a vulnerability assessment is down to the food packers misinterpreting the relevant clause in the BRC Food Standard 7. We have had requests from 3 or 4 customers for such an assessment to be carried out.

The part of the email update I copied into the thread was from the November 2015 BRC Newsletter, which I received on 30th November. I signed up to receive the newsletter via the BRC Global Standards website: http://www.brcglobalstandards.com/ . As a packaging supplier we find it useful to keep up with changes to the Food Standard as well as our own Packaging Standard so as to have some awareness of what our customers might be requiring from us.

 

Regards

Andrew



Charles.C

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Posted 08 December 2015 - 10:03 AM

Hi Andrew,

 

Thks for yr clarification.

 

I did have a look round the BRC site after yr previous post but didn't find a link to this issue.

 

Googling was more sucessful. It's there as you say.

 

Very useful indeed. Many thks.


Kind Regards,

 

Charles.C


kchukes

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Posted 04 February 2020 - 06:52 PM

As of BRCGS Issue 6 Packaging Materials, the BRC Standard does now require a formal vulnerability assessment for packagers – specifically as regards food fraud:

 

3.8.2

A documented vulnerability assessment shall be carried out on all raw materials or groups of raw materials to assess the potential risk of substitution. This shall take into account:
 
  • historical evidence of substitution
  • economic factors which may make substitution more attractive
  • ease of access to raw materials through the supply chain
  • sophistication of routine and upstream testing to identify substitution
  • nature of the raw material
The output from this assessment shall be a documented vulnerability assessment plan. This plan shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risks. It shall be formally reviewed annually.


Charles.C

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Posted 04 February 2020 - 11:43 PM

 

As of BRCGS Issue 6 Packaging Materials, the BRC Standard does now require a formal vulnerability assessment for packagers – specifically as regards food fraud:

 

3.8.2

A documented vulnerability assessment shall be carried out on all raw materials or groups of raw materials to assess the potential risk of substitution. This shall take into account:
 
  • historical evidence of substitution
  • economic factors which may make substitution more attractive
  • ease of access to raw materials through the supply chain
  • sophistication of routine and upstream testing to identify substitution
  • nature of the raw material
The output from this assessment shall be a documented vulnerability assessment plan. This plan shall be kept under review to reflect changing economic circumstances and market intelligence which may alter the potential risks. It shall be formally reviewed annually.

 

 

5-year old thread. Times change.


Kind Regards,

 

Charles.C


kchukes

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Posted 04 February 2020 - 11:46 PM

Are we not supposed to update old threads? Just askin'; I'm new here.



Charles.C

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Posted 05 February 2020 - 12:21 AM

Are we not supposed to update old threads? Just askin'; I'm new here.

 

No problem at all /  It's up-to-you, but to avoid confusion, maybe add an explanatory "footnote" if thread is more than 1-year old.

 

Some topics tend to be visibly superceded by many surrounding threads.

 

PS - I usually add a "thanks anyway" but I forgot this time. :smile:


Kind Regards,

 

Charles.C


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kchukes

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Posted 05 February 2020 - 12:44 AM

Understood, and the guidance is certainly appreciated!

 

 

Best,

KC






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