2 replies to this topic

[beersafety]

Hi there!

this is a BRC related inquiry.

I am wondering what secondary packaging approval and monitoring criteria should be.  

 

For raw materials we currently require GFSI third party certification, or questionnaire (for low risk only), and COA or COC. However, I am having trouble imagining these criteria working with items like cartons, labels, code ink, and hi-cones.

 

the BRC Issue 7 interpretation guide states:

3.5.1 - "all materials brought on to the site to become part of the final product (including packaging) must be sourced through approved suppliers and monitored. this approval process and programme for monitoring raw materials will consider the potential risk the material represents (in terms of safety, quality, and legality)" 

 

finally, the standard interpretation guide only identifies "(3.9.1)printed outer packaging" to be included in the traceability requirements, in regards to secondary packaging. So, that would mean the hi-cones, bottle labels, code ink, plastic wrap, pallets, etc. do not require to be traced, is that correct? 

 

If anyone can simplify this for me, giving me a basic idea of what sort of approval and monitoring program one develops for boxes, labels, code printer ink, etc., it would be greatly appreciated!

 

many thanks!!

[Anika]

Hi

 

BRC interpretation of primary packaging is stated below:

 

Primary packaging: "The packaging which constitutes the unit of sale, used and disposed off by the consumer, (e.g. bottle closure and label)"

 

Basically anything that goes to be consumer not just the customer is considered primary packaging and that could include the label, and cartons as well.

So then, clause 3.5 would apply to all packaging defined under the definition above except for the food fraud part:

 

http://coms.brcgloba...ail&utm_content

 

Check out these forums:

http://www.ifsqn.com...ity-assessment/

http://www.ifsqn.com...mary-packaging/

 

personally I think, based on risk assessments(packaging should be considered in RA's) questionnaires, allergen, chemical migration letter or FDA or CFIA compliance would suffice in the absence of third party audits or on site audits IMO

[beersafety]

thank you for your response and the links!

wow! so much great information.