Product packaging has been risk assessed for C/P/M/A in the hazard analysis as per 188.8.131.52 - "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?