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Anybody familiar with ISO17712 for security seals?

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#1 Angela5555

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Posted 24 January 2020 - 01:00 PM

Hi all,

 

Anybody familiar with ISO17712 for security seals?

BRC food standard including the interpretation guide  has a a very interesting position on what primary packaging is: “The packaging that constitutes the unit of sale to the consumer or customer (e.g. bole, closure and label of a retail pack or a raw material bulk container).”  We are both Food and Agents and Brokers certified and as a business we supply fruit juice, required for further processing however the food standard is pretty clear about what primary packaging is.

 

Security seals? How to I approve the supplier for security seals? Please correct me if im wrong, but the seals will automatically be classed as primary packaging. Furthermore, according to the standard, if the last packer is GFSI certified then no trace exercise is required however if theyre not GFSI  a trace exercise will be required as part of the approval process. Well....good on paper not so good in practice as majority of these suppliers are not familiar with the BRC or GFSI requirement.

Best call is to approve a security seals supplier based on ISO17712 however I'm not familiar with it as its such a niche market. Does the ISO scope cover the traceability element, I could probably persuade the supplier to provide a copy of their audit...

Any ideas please? How do you justify the approval for a supplier of this nature without being GFSI certified nor familiar with the trace exercise element? 

 

Help...


Edited by Angela5555, 24 January 2020 - 01:03 PM.


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#2 GMO

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Posted 28 January 2020 - 01:55 PM

Woah woah woah back up!  Is the security seal in touch with the product?  No?  Then it's not primary packaging.  Yes?  Then it's primary packaging.  If we're talking those loops of plastic you see sealing containers and lorries, not primary.  If we're talking a plastic seal which is removed to open a bulk container of juice and it was in contact with the ingredient before removal?  Yes primary packaging.

 

Next, if you're certain it is primary packaging, just stick to what the BRC standard wants.  It doesn't say you need ISO 17712 whatever that is.  What it says is that approval should be via GFSI or via some process which includes traceability.  So why not just go audit them and see what it's like?  It should be hygienically produced, have hand washing, allergen controls etc and traceability.  You can download the BRC standard for packaging (probably for free) as a guide but just pick out the key parts and trace.  It doesn't have to be all that complicated and will probably cost you one day out of the office (no scary ISO standards needed).



#3 Angela5555

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Posted 28 January 2020 - 02:36 PM

Drums for example - No food contact although primary packaging definition doesnt refer to food contact material....and that is the tricky bit. 

We have asked our BRC auditor to question BRC directly if we really need to go to this length, although it would meet their definition of primary packaging, it seems a little extreme to treat it as such. However, fast forward 6 months post V8 audit, we still don't have clarity on the matter  and as such as far as BRC is concerned, the security seals are classed as primary packaging as they're part of the unit of sale.

With regards to the supplier approval process, im aware of the approval process requirement however, those type of seals are not manufactured within the UK ( we are looking at Malaysia) and the manufacturers are not familiar with the food industry requirements, GFSI nor BRC hence, they've got no clue about traceability, allergens or GMP etc. So in these conditions, what are the options regarding supplier approval?

Please note, no security seals manufacturer exists within UK or Europe. 

 

You cant justify a trip/audit/visit to a supplier based in Malaysia when the business buys around 5000 seals/ tags per year...


Edited by Angela5555, 28 January 2020 - 02:37 PM.


#4 GMO

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Posted 28 January 2020 - 02:40 PM

 the security seals are classed as primary packaging as they're part of the unit of sale.

 

 

No that's not true.  Primary packaging is food contact and only food contact.  I'm not on site at the moment so can't give you a quote from the standard but if it's not in touch with the product it's not primary packaging.  A label on a prepacked sandwich is part of the unit of sale but not primary packaging, does that make sense?

 

What I'm not clear on is whether you are packing into the drums or receiving it like that?  Is it a bag in drum kind of arrangement? 



#5 Angela5555

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Posted 28 January 2020 - 03:10 PM

I totally agree with you but by the looks of it, BRC position on what primary packaging is has changed, please check the glossary definition: The packaging that constitutes the unit of sale to the consumer or customer (e.g. bole, closure and label of a retail pack or a raw material bulk container).

 

 

We are packing bulk/raw mats. required for further processing....it's a  bag within a drum closed with a lid and the security seal goes on the outside of the drum. 

 

Slightly controversial but that's how we got slapped with a non conformance...



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#6 GMO

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Posted 28 January 2020 - 04:18 PM

Interesting.  I will look again when I'm next on site with the interpretation guide but I would argue nobody is following this.  I can think of several examples where it would be ridiculous and will also increase lot tracking requirements on plant.  So far example someone selling a Christmas hamper with a bottle of port and a chunk of stilton (both fully packed before assembly) packed out with some wood wool will have to not only trace but have GFSI or audit approval for the basket, the wood wool, the film covering it, the bow on the top, any label... Come on BRC, really???



#7 Angela5555

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Posted 28 January 2020 - 04:48 PM

Extreme is an understatement....

The interpretation guide is another issue I'm afraid. It contains contradictory information regarding primary packaging (makes reference to food contact although the defintion in the glossary states otherwise). Our auditor at the time challenged it with BRC and they confirmed it doesnt quite match however, the standard must be followed and not the interpretation guide. Despite this, no formal position statement has been issued on the matter and we are chasing them for clarification on this since our previous audit.



#8 Fishlady

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Posted 01 February 2020 - 03:48 PM

I was told in a BRC approved class that “primary packaging” now covers “what the customer will take home.” In the case if bulk materials this could also include the rail car that delivered the bulk sugar. For retail products the concern seemed to be largely about the claims and such being made on the non food contact packaging, to ensure that the right printed material was matched with the right product. And also that the cereal might contact the inside of the box if the inner liner were torn, and things like that.



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#9 Leila Burin

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Posted 03 February 2020 - 03:37 PM

Hello,

pls look at the Q&A guidelines:

"SECTION 3.9: WOULD SHRINK WRAP AND PALLET SLIPS BE CLASSED AS PRIMARY PACKAGING? Primary packaging is defined as packaging that constitutes the unit of sale to the end consumer or customer. As shrink wrap or pallet slip sheets are not items that a consumer would see/take home, therefore, these items are not considered as primary packaging. 

However, when identifying primary packaging due consideration must be given to processes to minimise or eliminate any risk which may result in contamination of food product, for example: 
 – Using suitable food contact materials  – If the food contact material is a permeable substance, then anything stuck onto the surface should also be considered    (migration of inks through cardboard for example, is a well-documented risk which has affected a range of packing).
 
As a general rule, the Standard would not expect transit materials to be classed as primary packaging for example, pallets, pallet wrap, any label on the outside of the pallet wrap, etc"
 
hope ths helps..
best regards,
Leila


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#10 Angela5555

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Posted 03 February 2020 - 04:52 PM

Thank you for sharing Leila.

Unfortunately my query above refered to security seals (closing of a drum) not shrink wrap, pallets etc. We provide material in bulk required for further processing  and as per the above we got slapped with a NC due this reason. Currently, i'm still waiting for confirmation in writing from BRC with regards to this as its not clear cut. 

The packaging that constitutes the unit of sale to the consumer or customer (e.g. bole, closure and label of a retail pack or a raw material bulk container)



#11 Leila Burin

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Posted 03 February 2020 - 05:39 PM

Hello, I understand, but it is the same concept: IT DOES NOT APPLY.

 

BRCV8 new primary packaging concept only applies to product direct to consumer, no intermedia products, where primary packaging still is the one in contact with the product.

 

I did the ATP course in BRC some weeks ago and that was explained. No, it is not written - yet,

 

Anyhow, you shall have an answer from JF, BRC, and that NC shall be discarded...

 

best regards,

Leila



#12 GMO

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Posted 05 February 2020 - 10:02 AM

I think this is a really interesting topic.  I've learned something.  It says there in black and white in the standard Leila:

 

Primary packaging The packaging that constitutes the unit of sale to the consumer or customer (e.g. bottle, closure and label of a retail pack or a raw material bulk container).







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