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Non-Food Contact Packaging Traceability- SQF Quality Code Upgrade

SQF Quality Code packaging traceability non-food contact

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#1 muncys

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Posted 25 April 2019 - 01:02 PM

Hi all,

 

Long time lurker, first post.  My facility is a medium sized flavor ingredients and beverage manufacturer.  We are currently SQF Manufacturing Code certified and are looking to obtain SQF Quality Code certification.

 

Manufacturing Code 2.6.2.1 states: “Finished product is traceable to the customer (one up) and provides traceability through the process to the manufacturing supplier and date of receipt of raw materials, food contact packaging and materials and other inputs (one back);”

 

Looking at Quality Code 2.6.2.2 it says: “All raw materials, ingredients, and packaging materials used in manufacturing a finished product, and processing aids associated with the product, shall be identified with the finished product lot number and traceable back to the supplier (one back).”

 

The only deficiency my facility has for this point is that non-food contact packaging is not traceable.  For example, we produce beverage concentrates that get packed into a bag, which is traceable, and that bag gets packed into a box, which is not traceable.

 

Do we need to make non-food contact packaging traceable for Quality Code compliance?  If so, what are the implications for other packaging materials like tape and printed labels, etc.? I read the guidance and I am still unsure about this.

 

Thank you in advance for your help!



#2 Lesley.Roberts

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Posted 25 April 2019 - 03:50 PM

Hi all,

 

Long time lurker, first post.  My facility is a medium sized flavor ingredients and beverage manufacturer.  We are currently SQF Manufacturing Code certified and are looking to obtain SQF Quality Code certification.

 

Manufacturing Code 2.6.2.1 states: “Finished product is traceable to the customer (one up) and provides traceability through the process to the manufacturing supplier and date of receipt of raw materials, food contact packaging and materials and other inputs (one back);”

 

Looking at Quality Code 2.6.2.2 it says: “All raw materials, ingredients, and packaging materials used in manufacturing a finished product, and processing aids associated with the product, shall be identified with the finished product lot number and traceable back to the supplier (one back).”

 

The only deficiency my facility has for this point is that non-food contact packaging is not traceable.  For example, we produce beverage concentrates that get packed into a bag, which is traceable, and that bag gets packed into a box, which is not traceable.

 

Do we need to make non-food contact packaging traceable for Quality Code compliance?  If so, what are the implications for other packaging materials like tape and printed labels, etc.? I read the guidance and I am still unsure about this.

 

Thank you in advance for your help!

 

 

 

Hi Muncys

 

This may not help & may actually confuse,  I work to BRC & their definition of primary packaging is the unit that is sold to a customer - thus BRC would consider your box to be "primary" packaging (albeit not food contact)

 

https://www.ifsqn.co...dary-packaging/

 

Recording traceability of such materials would be useful as, if their are ever taint issues (it does happen), your recalls would be smaller & less product affected

 

Hopefully there will be forum members that have more direct knowledge of what SQF judge to be "packaging" related to clause 2.6.2.2?...



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#3 SQFconsultant

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Posted 25 April 2019 - 05:18 PM

No, it won't get into outer tapes, etc.  However, I don't understand why the non-food contact box never came up in an audit because you don't trace these items.

 

Every single one of our clients traces - every packaging piece in the event of a chemical hazard etc where components of the non-contact package could leach/migrate etc to the food contact packaging.


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF Full System Development & Implementation Consultant

You can DIY or Bring in the Professionals - We are done in 30 days

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

Remote & On-Site/Analysis of Operational & Capital Needs

Internal Auditor Training Program / eConsultant w/annual review

772.646.4115 // glenn@glennosterconsulting.com

Travel Base: Orlando, Florida USA

Home: Boquete, Chiriqui Panama

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 


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#4 Kerry785

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Posted 26 April 2019 - 06:03 PM

Our corrugate boxes come with a lot number printed on a flap (bottom) this number is also on paperwork that comes with the shipment. Our product is packaged bag in a box. The box doesn't contact the food, but our SQF auditor confirmed it was GRAS (Letter). It also has a specification sheet.



#5 crisescu

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Posted 26 April 2019 - 07:42 PM

Hi Muncys

as Lesley say, I also work with BRC, and in the new issue we have to trace the boxes and labels.

 

If your boxes don't have attached a label with the batch number, you should create an internal label of "entry of packaging" and give a lot number related to the shipping documents of that product.

Regards



#6 muncys

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Posted 26 April 2019 - 08:23 PM

Kerry785,

 

When you say your SQF auditor confirmed that your box was GRAS, did the auditor mean that you have to be able to trace the box or that you do not have to trace the box?







Also tagged with one or more of these keywords: SQF, Quality Code, packaging, traceability, non-food contact

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