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Is packaging classed as a raw material under ISO 22000 standard?


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#1 DiF

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Posted 06 June 2019 - 03:18 AM

Hi,

 

Is packaging classed as a raw material under ISO 22000 standard?

 

Thanks

Di



#2 mahantesh.micro

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Posted 06 June 2019 - 11:26 AM

Please elaborate your question..



#3 Charles.C

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Posted 06 June 2019 - 03:39 PM

Hi,

 

Is packaging classed as a raw material under ISO 22000 standard?

 

Thanks

Di

 

Hi Di,

 

As per previous post, can you specify a clause ?

 

eg 8.2.4.f has -

 

f)  supplier  approval  and  assurance  processes  (e.g.  raw  materials,  ingredients,  chemicals  and packaging);

 

 

 

So for above clause packaging is presumably not a "raw material".


Kind Regards,

 

Charles.C


#4 DiF

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Posted 06 June 2019 - 10:39 PM

Hi,

 

Clause 8.3, this is under the  ISO 22000 - 2018 standard.

 

Thanks

Di



#5 John_E

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Posted 07 June 2019 - 03:31 PM

Product-contact packaging is a raw material that should be traced like an ingredient and tested in the mock recall process.

 

-John



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#6 Charles.C

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Posted 08 June 2019 - 10:55 AM

Product-contact packaging is a raw material that should be traced like an ingredient and tested in the mock recall process.

 

-John

 

GFSI agrees with you, eg -

 

Raw material  A component of a food, feed or packaging that has not undergone processing

 

.

In contrast Codex's HACCP development clearly separates (food) "raw materials" from "packaging"

 

The various FS Standards are somewhat semantically individualistic, sometimes causing confusion, eg BRC did include Packaging in their Glossary definition of "raw materials" (RM) however "RM" when used for their vulnerability assessment excluded packaging. The resulting confusion took around a year to resolve !

 

Returning to Traceability -

 

BRC has -

 

Traceability - FUNDAMENTAL
The site shall be able to trace all raw material product lots (including primary packaging) from its suppliers through all stages of processing and dispatch to its customers and vice versa.

 

 

.

SQF has -

 

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);

 

 

ISO 22000 has - 

 

8.3  Traceability system
The traceability system shall be able to uniquely identify incoming material from the suppliers and the first stage of the distribution route of the end product. When establishing and implementing the
traceability system, the following shall be considered as a minimum:

a)  relation of lots of received materials, ingredients and intermediate products to the end products;
b)  reworking of materials/products;
c)  distribution of the end product.

 

Compare these additional extracts from ISO 22000 -

 

3.20, Note 2 to entry: The food chain also includes the production of materials intended to come into contact with food or raw materials.

 

 

To maintain the effectiveness of the FSMS, the organization shall ensure that the food safety team is informed in a timely manner of changes in the following:
a)  products or new products;
b)  raw materials, ingredients and services;
c)  production systems and equipment;
d)  production premises, location of equipment and surrounding environment;
e)  cleaning and sanitation programmes;
f)  packaging, storage and distribution systems;

 

8.5.1.2 The organization shall ensure that all applicable statutory and regulatory food safety requirements are identified for all raw materials, ingredients and product contact materials.

 

 

The preceding 3 examples IMO suggest that ISO chose to exclude "Packaging" from their interpretation of "Raw Materials".

 

However para 8.3 only refers to "material(s)" so I would assume that Traceability includes Packaging (possibly only product contact packaging)

 

Additionally, I found this (supporting) extract from iso22004 (2014) -

 

Traceability is a tool that allows organizations to track their end products forward, and raw materials, packaging or ingredients back through the supply chain. It is considered as a basic for food safety.

 


Kind Regards,

 

Charles.C


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#7 Zeeshan

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Posted 11 June 2019 - 05:41 AM

100% agreed.

 

 

....................ISO chose to exclude "Packaging" from their interpretation of "Raw Materials".

 

However para 8.3 only refers to "material(s)" so I would assume that Traceability includes Packaging (possibly only product contact packaging)



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#8 Zeeshan

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Posted 11 June 2019 - 05:47 AM

One thing to add. Wherever i found any term or concept confusing, i adopt the rule - "Make it simple and general". Take this case as an example - No matter which standard says what - Make your own simple definitions and document them in your manual / procedure. I think no reasonable Auditor will object on it as far the requirements are fulfilled appropriately - Traceability for example in this case.



#9 DiF

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Posted 23 June 2019 - 09:43 PM

Hi Charles C.

 

Thanks very much, good information.  I view would be to trace packaging, but needed some advice to ensure I was on the right track.

 

Di

 

 

Hi Di,

 

As per previous post, can you specify a clause ?

 

eg 8.2.4.f has -

 

 

 

 

So for above clause packaging is presumably not a "raw material".



#10 DiF

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Posted 23 June 2019 - 09:46 PM

Thank you all for your understanding of Raw Material.  Some standards are very black and white, while others leave it up for interpretation.  It makes sense to include packaging.

 

Cheers

Di 



#11 Charles.C

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Posted 24 June 2019 - 03:43 AM

One thing to add. Wherever i found any term or concept confusing, i adopt the rule - "Make it simple and general". Take this case as an example - No matter which standard says what - Make your own simple definitions and document them in your manual / procedure. I think no reasonable Auditor will object on it as far the requirements are fulfilled appropriately - Traceability for example in this case.

 

Hi Zeeshan,

 

Auditors in yr area may be of an unusually flexible species. :smile: IMEX, most  have case-hardened viewpoints/check-sheets as to the scope of responses which the Standard requires so as to enable the Auditor to tick his boxes. Significant omissions/discrepancies >>> NCs.

 

Auditee Interpretive differences of opinion are likely to be brushed aside unless one has concrete supporting evidence and sometimes even then.

 

I agree that the textual requirement(s) of some Standards is occasionally ambiguous, often due to attempted generically valid statements. I suggest that in order to maximise value of the Standard,  it is preferable to, at least initially, definitively  resolve such "confusions" rather than to "by-pass" them although I admit that the former option is not always the simplest.


Kind Regards,

 

Charles.C





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