Food safety ramifications of re-usable food contact packaging

I am a food contact packaging manufacturer of a primary packaging component with intermittent food contact. We send our product to food manufacturers. Our product itself is contained in packaging materials. Several customers have asked about the potential to send me my packaging material back for re-use. Given the packaging material goes into different food manufacturers, we don't presently accept the material back due to risk of allergens and contaminations. I have been asked to investigate Food Safety ramifications if such a program was put into place and what we should need for Food Safety to ensure we sustain Food Safety and keep our product safe. In-order for re-use, the packaging would have to be cleaned and sanitized to remove any possible allergens or potential micro-bio risks as being in a raw meat or food environment. What sort of certification or chain of custody would be needed for the incoming materials, once cleaned?

Could you please provide some more information on the type of packaging, what is contained within, etc.

Thanks.

Sure-

We supply our product wrapped around a plastic spool that is sent to our customer. The customer is looking to send us back the spools for re-use. Spools vary in material composition from HDPE to some few with polystyrene in them.

Sure-

We supply our product wrapped around a plastic spool that is sent to our customer. The customer is looking to send us back the spools for re-use. Spools vary in material composition from HDPE to some few with polystyrene in them.

Great, thanks - that provided the clarity I needed.   I've had a client in the past that did re-use on Spools.

They would take them back into a secured sanitation area and sanitize them. After which they were dried out and than swabbed for potential issues.

It's worked out just fine - a bit of documentation however will be needed but can easily be created having to do with tracing where they go, how they go, how they used, how they are returned, received, sanitized and swabbed - and then placed back into service and of where they go around and you start the whole documentation trial over again.

This is like reusable super sacks - there are some potential nightmares, however a good trial and good records/SOP with a upfront Risk Assessment would need to be undertaken - I don't know if other manufacturers would share the details with you, but if they did you should ask around as to how they went about doing the risk assessment part.

Hope that helps.

So- I have a question still-

If we have a third party clean and sanitize the spools, would that alleviate my company from having to trace where the spools were received from?- Since we would receive from the third party?

Meaning:

 If we clean and sanitize: we'd have to trace where the spools came inf rom (meat, cheese, powder, nuts, etc ) for allergen contaminations;

BUT,

If a 3rd party took them in, cleaned and sanitized, then the ownership as to where they came from reverts tot he 3rd party and I only need to keep track of where I send the spools to (as part of regular traceability) but keep track of the lot which they came in from on the 3rd party, right?

Lastly- is it advisable to get a disclaimer signed in acceptance of a re-used spool for liability of potential cross-contaminations risk?

Please let m e know-

I think I know the answer, but need a sound board so to speak.

Thanks

Follow the spool, regardless of whether you have an approved contractor doing the sanitation for you, we've seen way too companies think they are invisible to issues if they have others doing different things - you get a loss of control that way and that is not a good place to be.  

I don't know what the value of a siged disclaimer would do.