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Question regarding control of production levels


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#1 Formularon

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Posted 15 February 2018 - 11:33 PM

We are a plastic packaging manufacturer and we have obligated to obtain GFSI certification this year. We are looking at BRC and FSSC 22000. We have paid for the BRC scheme and had been moving down that path but realized one requirement was you cannot mix control levels in the same production area. While it is physically not a problem, we could simply elevate all our requirements to food contact packaging levels, it is a business problem. We currently produce many products that are non-food grade and are manufactured with reprocessed resin. The resin is processed at an external recycling facility using our scrap but we do not control what else they process or have trace-ability to source for our scrap as it is all mixed and would be a nightmare to track. So under BRC we would have to make a business decision to eliminate or raise the price of these non-food grade products since we would have to utilize virgin resin. Does anyone know if FSSC 22000 requires a similar level of control in production areas? Additionally am I interpreting the BRC requirements incorrectly?

Thanks in advance.



#2 JoGriffiths.BRCGS

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Posted 22 February 2018 - 10:06 AM

Hi, 

There's no reason why you shouldn't continue to use your reprocessed resin as a raw material, BRC does not mean you can't use recyclate, which typically doesn't pose a risk of itself. 

 

Yes, you'll need to use high hygiene requirements across your site if you'r producing food contact materials but the BRC Standard is risk-based which means you can use your knowledge of your process(es) and facility to determine how best to mitigate risk to the consumer. If you identify there is a potential for the other materials processed at the external facility to pose a risk to your process and product safety and quality then you can put systems and procedures in place to manage that risk, which is probably what you're doing anyway. They key with BRC GS requirements is to document everything, from your Hazard and Risk Analysis through to the specific procedures you have in place. 

 

I hope this eases your worries a little, but if you'd like more clarification you're more than welcome to contact us at BRC Global Standards, either here or through our enquiries@brcglobalstandards.com inbox. 



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#3 Tony-C

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Posted 24 February 2018 - 06:06 AM

Hi Formularon,

 

:welcome: 

 

Welcome to the IFSQN forums.

 

An interesting 1st post.

 

I don't think that FSSC 22000 certification is likely to be any less demanding, for example in ISO/TS 22002-4:2013 Prerequisite programmes on food safety -- Part 4: Food packaging manufacturing section 10 Contamination and migration states:

Mixing of raw or intermediate materials shall be prevented where hazard assessment reveals a food safety hazard.
 
My questions would be:
What hazards are associated with the reprocessed resin?
What degree of segregation is there?
What controls are in place?
 
Kind regards,
 
Tony

 

 

 






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