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Documented procedure for disposal of Trademark packaging product


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#1 epeabody

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Posted 03 January 2020 - 03:58 PM

The Food Packaging Manufacturing Company I work for is working towards an SQF Certification and we recieved a minor non-compliance during our GAP Audit under 2.5.4.6. This section discusses the controlled disposal of trademarked food packaging product. Our auditor told us we needed to have a documented procedure that includes who and how often, if a contracted service is used, and the disposal process. I just recently made contact with the company we contract for this service and this was the information I got back:
 

 

We do not have a formal written agreement.

 

All non-baled, non-shredded printed sheets and/boxes are transported securely to their local facility where they are sorted/shredded/baled securely before being transported to their customers.  Non-conforming printed materials, if any, are disposed securely.

 

 

 

Is this process (conducted by an outside company) sufficient for the SQF requirement?

 

Do I need to obtain some formal document from our service provider stating their process?

 

Do I need to write a document for my company explaining the steps?

 

 

 

Any guidance would be greatly appreciated. Thank you.



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#2 SQFconsultant

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Posted 03 January 2020 - 06:44 PM

We do not have a formal written agreement.

 

> Need a formal agreement.

 

 

 

Is this process (conducted by an outside company) sufficient for the SQF requirement?

 

>Not really, there explanation while sufficient for them is vague --  you need them to explain in writing how they are going to process YOUR packaging and of course in turn your customers packaging to render it un-usable.

 

 

Do I need to obtain some formal document from our service provider stating their process?

 

> Yes.

 

Do I need to write a document for my company explaining the steps?

 

>Yes


Kind regards,

 

Glenn Oster
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

SQF, BRC & IFS System Development, Implementation & Certification Consultants

Serving Small-to-Mid-Size Businesses | We are International - Accepting all major C-Currencies

Internal Auditor Training | eConsultant | SQF, BRC & IFS Pre-Development or Pre-Audit GAP

http://www.GlennOsterConsulting.com  -- 

 

 

60% Savings to Ownership/Senior Partners when using C-Currency "XRP" Expires: 04-NOV-20

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#3 AC2018

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Posted 03 January 2020 - 08:01 PM

We received a finding for this as well on our last audit. Our current trash company does not have a process and can not supply us with a written agreement. What I did instead was wrote a policy basically saying that if we need to dispose of trademarked goods we will find a company that can securely destroy our trademarked goods and supply evidence of destruction. (This is not something we dispose of frequently so this statement works for us). I also included in our policy that if it is a small amount that needs to be destroyed that we may elect to destroy them in house e.g. a roll of labels that are obsolete, using a sawzall to cut through them. I then created a form to fill out internally with signatures of different employees and other needed information to capture. 

 

Hope this helps! 



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#4 epeabody

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Posted 06 January 2020 - 12:10 PM

Thank you for you responses; this was very helpful.



#5 Hoosiersmoker

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Posted 08 January 2020 - 02:04 PM

We require a Letter of Destruction from all waste companies / recyclers we use for our trademarked waste. We actually drafted an agreement that they return to us in the form of a letter (See attached). We have been using this method for 5 years and has passed scrutiny every time.

Attached Files






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