4 replies to this topic

[StevieP]

Quick question to throw out there today.

 

I've just had my procurement manager advise that one of our customers who we supply sweet mixes to wants to change his packaging format which would mean there's a lid and base, but there's currently not seal on the lid and base to prevent tampering or malicious contamination. We have suggested we apply tamper tape. The customer does not want any form of tamper seal because they claim sweet pots are stacked on top of each other, so no one would tamper etc (not convinced).

 

From a TACCP perspective how would I get around the non-sealing of primary packaging? And protect my due diligence defence?

 

Thanks.....

[SQFconsultant]

I'm not convinced as well.  

 

You have to make a decision if you want to comprimise your own policy

 

You could always write up an exception notice that it goes against your policy to do so and that once the product leaves your facility you accept no liability whatsoever for the product and the customer is required to sign the statement that they have asked for no security sealing and they take full responsiblity for the product from the moment it leaves your facility.  

 

Now, that sounds pretty good - however I doubt they would sign a statement like that.

 

So, after you transmit that to them and they decided not to do so, you go ahead and plan on securing their products.

[StevieP]

Thanks, my thoughts are exactly on the same line. Not comfortable at all.

 

The other thought that crossed my mind was one of average weight. If there's no tamper seal, I cannot control tampering which may impact on average weight legislation. And so, technically, through tampering could be breaking average weight legislation.

[annacortes]

My suggestion would be to explain to your customer the reason why you are requesting this change; use the requirements of the Food Safety/Quality Plan you may have written per guidance of GFSI and your company's Approved Supplier Program. It is always helpful to include any reference of regulatory information when requesting changes to a customer. Assure you focus on the benefits to the Customer(s) in requesting the change. Always begin your communication; I am requesting the following addition or change in your process based on ...... reference  internal risk assessment scoring, a new policy release, or new regulatory release. End your communication " We appreciate the support of  " Our Company's" food safety and quality programs.

 

If the Customer(s) response is still leaning towards not wanting to comply with your request; I would suggest you reach out to your Company's Senior Management group and inquire about offering the customer financial asst if the refute has to do with cost that will be incurred.

 

As mentioned prior you could write an exception based on a completed risk assessment showing there is no or very little risk to your company and the end consumer; however I do not recommend this route when it comes to tamper proof sealing without very strong evidence to support " no risk".

 

The last option ; which is highly not preferred or recommend is to inform your customer if the change is not made per your Company's Food Safety Program's Approved Supplier Program; and Food Defense-Food Fraud program requirements receipt of the goods would have to seize until a proven method could be verified.

[StevieP]

Thanks for the feedback. I think for me as well, under the BRC standard, I need to be able to demonstrate that I've taken all reasonable precautions to mitigate malicious contamination. And personally, I think, a prepacked primary product without any form of security seal, leaves me vulnerable.

 

 

Thanks for the feedback though