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.
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.
