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FSQA

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Posted 12 December 2018 - 08:23 PM

Can anybody guide me to the correct regulation by USDA/FSIS for repacking of raw chicken in a distribution center?

 

Current scenario is that we receive fresh raw chicken in boxes (25-40lbs each) which are inspected and marked by USDA inspection at our approved supplier/USDA regulated facilities.

During handling at our operations, sometimes the outer casing/ paper box (with the USDA inspection label)  gets damaged , while the product primary packaging (which is without the USDA inspection mark) is still intact, with no exposure of the product to the environment. These boxes are removed from the inventory and disposed off immediately.

 

However, while revisiting the wastage, my understanding is that as long as the inner packaging is still intact and all the temperature and other food safety/traceability requirements are met and maintained, can these be repacked into new similar boxes, while the original USDA/Product label be transferred to the outside of the new box? Should one require to contact USDA/FSIS everytime this happens or this can be done as long as the records of it is maintained?

 

I have done a risk assessment on it, however, I am seeking the regulation side of it, so any help would be appreciated. 

 

 



Charles.C

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Posted 13 December 2018 - 02:51 AM

Can anybody guide me to the correct regulation by USDA/FSIS for repacking of raw chicken in a distribution center?

 

Current scenario is that we receive fresh raw chicken in boxes (25-40lbs each) which are inspected and marked by USDA inspection at our approved supplier/USDA regulated facilities.

During handling at our operations, sometimes the outer casing/ paper box (with the USDA inspection label)  gets damaged , while the product primary packaging (which is without the USDA inspection mark) is still intact, with no exposure of the product to the environment. These boxes are removed from the inventory and disposed off immediately.

 

However, while revisiting the wastage, my understanding is that as long as the inner packaging is still intact and all the temperature and other food safety/traceability requirements are met and maintained, can these be repacked into new similar boxes, while the original USDA/Product label be transferred to the outside of the new box? Should one require to contact USDA/FSIS everytime this happens or this can be done as long as the records of it is maintained?

 

I have done a risk assessment on it, however, I am seeking the regulation side of it, so any help would be appreciated. 

 

Hi FSQA,

 

Not in USA but this activity sounds "dodgy" and IMO likely officially  unacceptable. Why ? Because the action is equivalent to Labelling manipulation. Fraud ?

 

As I understand, a USDA regulated facility typically maintains USDA/QC representatives in attendance,, what do they say ?


Kind Regards,

 

Charles.C


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SQFconsultant

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Posted 13 December 2018 - 10:53 AM

The repackaging would be done in a distribution center with exactly the same type of packaging that the product was boxed in to begin with?

 

As in the chicken company put the packaged chickens into a #343 Box from XXX Company and you use the exact same box type from the same manufacturer?  

 

And you have express permission from the producer to do this operation?


Edited by SQFconsultant, 13 December 2018 - 10:54 AM.

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FSQA

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Posted 13 December 2018 - 02:29 PM

Hi FSQA,

 

Not in USA but this activity sounds "dodgy" and IMO likely officially  unacceptable. Why ? Because the action is equivalent to Labelling manipulation. Fraud ?

 

As I understand, a USDA regulated facility typically maintains USDA/QC representatives in attendance,, what do they say ?

Thanks Charles, I agree to your comments and those were my concerns too, though the intention is not of Food fraud but to avoid wastage of the product that (IMO) is maintaining aspects of Food safety and traceability. As I am unsure of the regulations, despite a search on it, I need to know the Do's and Don't in this regard before we initiate any changes in the current practices. I have reached out to local USDA/FSIS for further explanation and pending for a reply from them.

 

 

The repackaging would be done in a distribution center with exactly the same type of packaging that the product was boxed in to begin with?

 

As in the chicken company put the packaged chickens into a #343 Box from XXX Company and you use the exact same box type from the same manufacturer?  

 

And you have express permission from the producer to do this operation?

Thanks Glenn, yes if we adapt to that direction, it will be the same kind of boxes, and it will be requested only from the original processor of the product.

No, we have not reached out to the vendor yet on this regard, but will do once we figure out the regulation on it, if it can be done.



Scampi

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Posted 13 December 2018 - 02:56 PM

In Canada, you would require an inspector on site for this sort of re-packing

 

 

from FSIS

https://www.fsis.usd...pdf?MOD=AJPERES

 

"In slaughter plants, inspection personnel verify the humane handling of animals and conduct antemortem inspection to ensure that the live animal is fit for slaughter. These inspection personnel also conduct post-mortem inspection to ensure that the meat from the carcass and internal organs are fit for human food. When meat is distributed to other federally inspected establishments for further processing, the product is inspected to ensure that the product is safe, wholesome, and correctly labeled"

 

In all likely hood reboxing AND re labelling will qualify as "further processing" which will require inspection


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