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Should packaging be included on the vulnerability assessment in 5.4?


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#1 AFAIK

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Posted 01 October 2018 - 01:10 PM

Hi

Product packaging has been risk assessed for C/P/M/A in the hazard analysis as per 3.5.1.1 - "The company shall undertake a documented risk assessment for each raw material or group of raw materials including primary packaging to identify potential risks to product safety, legality and quality. This shall take into account the potential for:

- Allergen contamination

- foreign body risks

- micro contamination

- chemical contamination

- variety or species cross contamination

- SUBSTITUTION OR FRAUD (see 5.4.2)

 

However, section 5.4.2 does not mention packaging. I've had a BRC non conformance for not including packaging when it has been risk assessed for all of the above except substitution or fraud. How has everyone else dealt with this? Do you have packaging included on your vulnerability assessment?

 

Thanks



#2 pHruit

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Posted 01 October 2018 - 01:49 PM

Hi AFAIK,
I'm not able to answer your specific question but am very interested to see what experiences others have had - we had four audits against Issue 7 and were never asked about this, and do not have packaging in our vulnerability assessment.

The interpretation guides for both Issue 7 and Issue 8 suggest that this part can be done under 5.4.2 which as you say makes no mention of packaging...



#3 cfreeman

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Posted 01 October 2018 - 07:18 PM

Hello,
Yes you need to do a Vulnerability Assessment on your Direct contact packaging. Also, do one on Food Grade Lubricants



#4 Charles.C

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Posted 01 October 2018 - 09:49 PM

Hi

Product packaging has been risk assessed for C/P/M/A in the hazard analysis as per 3.5.1.1 - "The company shall undertake a documented risk assessment for each raw material or group of raw materials including primary packaging to identify potential risks to product safety, legality and quality. This shall take into account the potential for:

- Allergen contamination

- foreign body risks

- micro contamination

- chemical contamination

- variety or species cross contamination

- SUBSTITUTION OR FRAUD (see 5.4.2)

 

However, section 5.4.2 does not mention packaging. I've had a BRC non conformance for not including packaging when it has been risk assessed for all of the above except substitution or fraud. How has everyone else dealt with this? Do you have packaging included on your vulnerability assessment?

 

Thanks

 

Hi afaik,

 

I assume you refer to BRC7.

 

Unfortunately, regarding Packaging  Post 3 is categorically incorrect.

There is a long discussion on this Forum over BRC7/VA/Packaging which includes a copy of BRC's confirmation of "unrequired".

Just search a little.


Kind Regards,

 

Charles.C


#5 012117

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Posted 02 October 2018 - 12:59 AM

We have made one but not so detailed especially for PET bottles, we only the substitution using non virgin materials as compared to virgin ones. In this aspect, the virgin ones have lesser risk in terms of migration or serve as better barrier for migration for some type of packaging but that is all we have.



#6 Charles.C

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Posted 02 October 2018 - 01:13 AM

We have made one but not so detailed especially for PET bottles, we only the substitution using non virgin materials as compared to virgin ones. In this aspect, the virgin ones have lesser risk in terms of migration or serve as better barrier for migration for some type of packaging but that is all we have.

 

Hi 012,

 

Just to repeat.

Afaik, the Product in OP was Food.

VA/Packaging is not required.

 

If the Product is Packaging I have zero idea.


Kind Regards,

 

Charles.C


#7 012117

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Posted 02 October 2018 - 01:43 AM

Hi, Charles.

 

I understand. From my previous post in the forum, I share confirmation comments whether thing is required or not (as far as I recall for the standard), in this case I did not confirm but I said we have done something, but only for 1 packaging and just sharing the experience that even if it is not required, there could be risk from fraud.



#8 Charles.C

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Posted 02 October 2018 - 02:14 AM

Hi, Charles.

 

I understand. From my previous post in the forum, I share confirmation comments whether thing is required or not (as far as I recall for the standard), in this case I did not confirm but I said we have done something, but only for 1 packaging and just sharing the experience that even if it is not required, there could be risk from fraud.

 

Hi 012,

 

Thanks for the input.

 

More information this post/thread -

 

https://www.ifsqn.co...42/#entry131071


Kind Regards,

 

Charles.C


#9 Fishlady

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Posted 03 October 2018 - 08:10 PM

Would there be a concern with ore-printed packaging to be fraudulent? Perhaps improper use if a trademark?



#10 Charles.C

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Posted 03 October 2018 - 10:00 PM

Would there be a concern with ore-printed packaging to be fraudulent? Perhaps improper use if a trademark?

 

hi Fishlady,

 

I'm guessing you meant "over".

I would have thought such a blatant change more likely to simply be rejected at customs due legality. Similar to over-sticking labels.

 

However I'm sure there is no objection to your exceeding BRC's basic food fraud requirements if you so desire. No doubt the auditor will appreciate the additional work involved  also.


Kind Regards,

 

Charles.C


#11 Sharon (Dewsbury)

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Posted 07 November 2018 - 11:01 AM

Hi ,

just to share my experience on this.

Our customer was concerned about our waste printed cartons. Over produced stock and/or stock with miss prints.  He felt (rightly so) that the cartons  could be stolen and filled with any old product of the identified label. (i.e. cheap biscuits in a premium biscuits carton ) and sold in a market or car boot sale fraudulently. This was against a clause in the BRC for packaging (4.10.4 /5 trademark material security & disposal) I don't know what clause it would be in the food BRC . So even though the BRC doesn't require a vulnerability assessment for packaging it can creep into usefulness hidden in other clauses. IMO from the other side of the supply chain as a printed packaging supplier. 

 






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