Question, we are going to get our FSSC 22000 certificate because our customers want us to have it, however I am a bit confused by the law. I am a glass manufacturing plant and am considered GRAS by the FDA. I believe I am only have to comply with 21 CFR part 117 subpart b, which is CGMPs. The only thing I can find to support this is as follows from the FDA website:
FPM.1 Are food packaging manufacturers required to register with the FDA and comply with the preventive control requirements for Human Food?
In general, subparts C (Requirements for Hazard Analysis and Risk-Based Preventive Controls) and G (Requirements for a Supply-Chain Program) of the Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food rule (21 CFR part 117; 80 FR 55908)(CGMP & PC rule) apply to an establishment that is required to register with FDA as a food facility. For purposes of registration, food-contact substances are not considered “food,” and therefore do not trigger the requirement to register (see 21 CFR § 1.227).
FPM.2 Are food packaging manufacturers required to create and maintain a Food Safety Plan?
The manufacturing of food packaging is not subject to subparts C (including the requirement for a food safety plan) and G of the CGMP & PC rule. Other activities, such as placing food in the packaging, would require registration and be subject to subparts C and G, unless an exemption applies.
FPM.3 Do the Current Good Manufacturing Practices apply to a food packaging manufacturer?
The CGMP regulations in 21 CFR part 117, subpart B apply to the manufacturing of food packaging. These regulations address, among other things, the taking of adequate precautions to reduce the potential for allergen cross-contact and for contamination of food, food-contact surfaces, and food-packaging materials with microorganisms, chemicals, filth, and other extraneous material. Also, appropriate quality control operations must be employed to ensure that food is suitable for human consumption and that food-packaging materials are safe and suitable (see 21 CFR § 117.80(a)(2)).
Am I right to assume that by law I am covered with just the CGMP but for a certificate I have to be HACCP based but that is going above and beyond the law.