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BRC 3.11, Is traceability of all manufacturing materials required in printed packaging?

brc traceability packaging issue 6 recall

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#1 superior_QM

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Posted 27 May 2020 - 06:30 PM

My company is currently a manufacturer of paperboard folding carton food packaging. We are moving towards certification to BRC issue 6 for Packaging Materials. Most of the product we produce is indirect food contact. One debate we are having regards traceability. The standard says the following in 3.11:

 

The site shall be able to trace and follow all raw materials through processing (including subcontracted processes) to the distribution of the finished product (packaging material) to the customer and vice versa.

 

Most of our product consists of 4 types of raw material: paper, ink, coating, and glue. Currently we only have full traceability of paper from receipt of rolls and their Serial Numbers to consumption on individual jobs. For ink, coating, and glue, we have record of when the products were received and their corresponding batch numbers, but we do not trace the consumption of these batches to each job. So were there to be an issue with one of these raw materials, we would have to judge based on the timing when it was likely consumed, but we wouldn't know 100% exactly which jobs. Theoretically that would mean if there was a recall we would have to cast a wider net of returned product than if we traced to each job. But that is a risk we might be willing to accept.

 

My question is, do you think if we have a documented risk assessment of our raw material traceability (and the likelihood/severity of harmful issues with coating, glue and ink), that an auditor would accept this? Or will they expect that everything is traced to the same level as our paper?



#2 Ryan M.

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Posted 27 May 2020 - 07:22 PM

I can't speak to BRC specifically, but with SQF this would be acceptable.  I would think it would be acceptable with BRC as well since you can trace it, but with a wider net.  It is a business operational decision in this case and as long as your company and management accepts that then it works.



#3 SQFconsultant

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Posted 27 May 2020 - 09:09 PM

"My question is, do you think if we have a documented risk assessment of our raw material traceability (and the likelihood/severity of harmful issues with coating, glue and ink), that an auditor would accept this? Or will they expect that everything is traced to the same level as our paper?"

 

....

 

Yes, a BRC Auditor would accept this.

 

I would suggest having documentation as to what the ingredients are that make up the packaging - as a former BRC Auditor I'd take the risk analysis and review that, but knowing that you really have minimal control on these items for tracing I'd want to know what the impacts might be - let's just say for the heck of it, you tell me your packaging could be used to package gluten-free products - I'd want to see documentation on what the glue has in for it for instance.

 

So make  your risk analysis in-depth and you'll be fine.


Warm regards,
 
 
Glenn Oster
 
 
Glenn Oster Consulting / 800-793-7092 /  Serving the America's

SQF & BRC System Development, Implementation & Certification Consultant

We serve Small-to-Mid-Size Food & Food Related Businesses

Internal Auditor & PCQI Training|Weekly eConsultant|FoodSafeSQF|Remote GAP

 

www.GlennOsterConsulting.com

 

 

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http://​www.glennosterconsulting.com

 


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#4 Charles.C

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Posted 28 May 2020 - 01:31 AM

My company is currently a manufacturer of paperboard folding carton food packaging. We are moving towards certification to BRC issue 6 for Packaging Materials. Most of the product we produce is indirect food contact. One debate we are having regards traceability. The standard says the following in 3.11:

 

The site shall be able to trace and follow all raw materials through processing (including subcontracted processes) to the distribution of the finished product (packaging material) to the customer and vice versa.

 

Most of our product consists of 4 types of raw material: paper, ink, coating, and glue. Currently we only have full traceability of paper from receipt of rolls and their Serial Numbers to consumption on individual jobs. For ink, coating, and glue, we have record of when the products were received and their corresponding batch numbers, but we do not trace the consumption of these batches to each job. So were there to be an issue with one of these raw materials, we would have to judge based on the timing when it was likely consumed, but we wouldn't know 100% exactly which jobs. Theoretically that would mean if there was a recall we would have to cast a wider net of returned product than if we traced to each job. But that is a risk we might be willing to accept.

 

My question is, do you think if we have a documented risk assessment of our raw material traceability (and the likelihood/severity of harmful issues with coating, glue and ink), that an auditor would accept this? Or will they expect that everything is traced to the same level as our paper?

I suggest you invest in the BRC Interpretation Guidelines if they exist for Packaging.

 

For BRC Packaging does "shall" (always?) mean "must" ? That IMO is (or appears to be) the Question.

 

I daresay this query has been discussed on this Forum already ?


Kind Regards,

 

Charles.C


#5 pHruit

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Posted 28 May 2020 - 08:07 AM

Shall = must, and indeed the requirements for 3.11 are marked as "fundamental" in the standard, meaning that failing to meet them potentially means an failing an audit / decertification.
Whether they'd apply it so unequivocally if you're 98% compliant with the requirements is another question.

 

@superior_QM, if you don't yet have access to BRC Participate then it's very definitely worth paying for a copy of the interpretation guidelines from the BRC Bookshop: https://www.brcgsboo...ine-/c-24/p-590

Read the section on 3.11.1, as this discusses inks - they do note that "inks can be difficult to maintain with regards to traceability". Nonetheless it also states that "the site should, however, bear 'one step forward, one step back' in mind when considering traceability for inks." There is also discussion about composite batches, and this notes that they will accept a similar approach to food products in bulk silos, whereby the "best practical level of accuracy is acceptable."



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#6 Foodworker

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Posted 28 May 2020 - 11:02 AM

It is worth bearing in mind that there have in the UK and Europe been some very big product recalls because of migration of varnish and ink components into food, notably the Tetrapak ITX issue and several due to methylbenzophenones in what looks like very similar product ranges to yours.

 

This is one of the reasons that the BRC Packaging Standard expects traceability on inks etc.



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#7 Hoosiersmoker

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Posted 28 May 2020 - 12:27 PM

If you formulate / mix your own colors in house this becomes quite the issue and very difficult and your risk assessment would need to bear out the level hazard clearly. If you use primarily process colors or your manufacturer formulates to Pantone it's much easier. Our suppliers (Sun and Wikoff) supply custom and Pantone colors specifically for us, offset and flexo, and barcode all ink information on each container (cartridge, bucket, barrel or tote) and we scan / record at job start and every container used during the run and weigh the remaining partials for each color at job close. This gives us manufacturer, lot, color, dates and exact amount used. One step back is easy, obviously the manufacturer, one step forward is the customer for us. Glue, ink, film and paper mfg's were all on board with bar coding all materials for us for traceability.

 

Do you window any of your products? Your films would also be raw materials as well as hot melts (if used) and window glues.

 

I'm always more concerned about a glue recall... 40 gallons of glue for us can be used to glue cartons across several runs and if we buy 4 or 8 barrels at a time it could be a month's worth of products!



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#8 Hoosiersmoker

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Posted 28 May 2020 - 01:07 PM

I forgot to mention, we are SQF with Food Quality certified and our traceability has never been deemed deficient. Our last traceability exercise, during our last audit, took about 5 minutes. Our company has done an outstanding job with data collection, live inventory and traceability!



#9 superior_QM

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Posted 28 May 2020 - 03:48 PM

Shall = must, and indeed the requirements for 3.11 are marked as "fundamental" in the standard, meaning that failing to meet them potentially means an failing an audit / decertification.
Whether they'd apply it so unequivocally if you're 98% compliant with the requirements is another question.

 

@superior_QM, if you don't yet have access to BRC Participate then it's very definitely worth paying for a copy of the interpretation guidelines from the BRC Bookshop: https://www.brcgsboo...ine-/c-24/p-590

Read the section on 3.11.1, as this discusses inks - they do note that "inks can be difficult to maintain with regards to traceability". Nonetheless it also states that "the site should, however, bear 'one step forward, one step back' in mind when considering traceability for inks." There is also discussion about composite batches, and this notes that they will accept a similar approach to food products in bulk silos, whereby the "best practical level of accuracy is acceptable."

 

After some of the comments here I did purchase the interpretation guidelines and it looks to be pretty helpful. Thanks for the tip. I'm thinking I will need to get with me team and see if we can at least make an attempt at capturing some additional data of what batches get used, maybe even just a daily log.



#10 superior_QM

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Posted 28 May 2020 - 03:52 PM

If you formulate / mix your own colors in house this becomes quite the issue and very difficult and your risk assessment would need to bear out the level hazard clearly. If you use primarily process colors or your manufacturer formulates to Pantone it's much easier. Our suppliers (Sun and Wikoff) supply custom and Pantone colors specifically for us, offset and flexo, and barcode all ink information on each container (cartridge, bucket, barrel or tote) and we scan / record at job start and every container used during the run and weigh the remaining partials for each color at job close. This gives us manufacturer, lot, color, dates and exact amount used. One step back is easy, obviously the manufacturer, one step forward is the customer for us. Glue, ink, film and paper mfg's were all on board with bar coding all materials for us for traceability.

 

Do you window any of your products? Your films would also be raw materials as well as hot melts (if used) and window glues.

 

I'm always more concerned about a glue recall... 40 gallons of glue for us can be used to glue cartons across several runs and if we buy 4 or 8 barrels at a time it could be a month's worth of products!

 

Sounds like we have very similar processes, but we have both in-house ink mixing and pantone colors supplied by our vendor. There are barcodes and batch numbers, the concern is just the level of effort to accurately capture this information on each job. Especially for process colors.

 

Windowing is rarely used on our product and is outsourced when we do it. But I agree about your glue concerns - any issue would cover a lot of product for us.



#11 Hoosiersmoker

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Posted 28 May 2020 - 04:13 PM

Do you currently use any type of data capture like barcode scanners and inventory type software? If so, usually you can expand the software (modules) to accept scans and tie it in to your inventory. If you can get that set up the traceability is simple as you can feed that data capture into each job and have all raw materials linked to each job. Our system has become encompassing - Every raw materials, WIP, and finished skid is scanned to a specific location so we can physically locate, count and verify anything at any given minute. It has save us a fortune in searching for and double ordering raw materials and over running product due to inability to locate. In the process it gave us an immediately searchable database for all components, finished goods, suppliers and customer inventory. It's why we did the traceability exercise in 5 minutes during our audit last year and our "Mock" recall in less than 30 last year. We have one manufacturing and 2 remote warehouses, all linked and live.







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