11 replies to this topic

[detario]

Hello, my company is very environmentally friendly, and they want to reuse cardboard boxes that we receive our packaging in to ship out finished product.  They want to know if this is allowable under NSF and GMP guidelines, and I haven't found anything stating that we can't do it but it seems a little iffy to me.  I told them we shouldn't use any that already have printed labels on them but that I would check about plain boxes.  If anyone could shed some light I would appreciate it.

[olenazh]

I've never heard of that: how are you going to trace your packaging? How can you be sure that re-used packaging is not affecting food safety - especially in case of complaints? Also, you're supposed to have all information on file for the materials you're using in your production, including packaging. (e.g. material specifications, drawings, permits, etc.) There could be more questions arising from this situation - are you or your management sure caring for the environment is more important than food safety and compliance to regulatory requirements?

[MDaleDDF]

If you want to be green, recycle.   Even outside of guidelines, it would just look cheap to me.   Definitely a no go here....

[TimG]

Good morning Detario.

You are going to want to check the NSF standard you operated under, there are tons ranging from water chemicals to plastic fittings. As far as FDA regulated GMP's:

21 CFR § 110.37 Sanitary facilities and controls.

Plant construction and design. Plant buildings and structures shall be suitable in size, construction, and design to facilitate maintenance and sanitary operations for food-manufacturing purposes. The plant and facilities shall:

(1) Provide sufficient space for such placement of equipment and storage of materials as is necessary for the maintenance of sanitary operations and the production of safe food.

(2) Permit the taking of proper precautions to reduce the potential for contamination of food, food-contact surfaces, or food-packaging materials with microorganisms, chemicals, filth, or other extraneous material.

 

I laud your company taking proactive steps toward 're-use,' as 'reduce>reuse>recycle,' but you would have to make sure you meet the above requirements for contamination.

[Scampi]

hard no for all the reasons above plus an eeeeew factor

[SQFconsultant]

Tgis does not fly, in the lonf term and have seen it artempted a nunber of tines. Better to dind anoyher way ti shave pennies.

[detario]

Thank you all for the responses!  It did not sit well with me either (I'm a strong proponent of environmentalism as well), and I appreciate the clarity.  Currently trying to convince them to use a compactor and recycle it, we may be able to get a small amount of money this way also.

[Ryan M.]

For clarity...this is secondary / tertiary packaging correct?  It seems all the responses are pointing to it being primary packaging, but seems like it isn't.

 

It's a unique situation, and you can run into product identification and labeling issues at your customers.  Do you ship to DC's? Retailers? Other?

[detario]

Yes, this is the boxes used by our shipping dept./warehouse.  Everything is finished product in packaging that has all been qc checked, then it is put in the shipping boxes afterwards.  The only time we would use this practice is when we were shipping to a company that contracted us to make certain products for them.  The boxes used to ship would either be plain or the ones originally used to send us the bottles that we eventually fill.

[Ryan M.]

I really don't see the big issue then.  So long as you keep the boxes dry and protected.

 

How many of you have been to a cardboard manufacturing facility?  lol....eegad.....

[Abby7]

Hello:

 

We are SQF certified and pack frozen product into bulk cases which are lined with new LDPE bags during our fresh-frozen season.

When we are freezing out of spec fruit that we know will need to be re-inspected on site before it can be packed for retail, we will re-use bulk cases - maximum of 3 times (they are lot coded each time).

But we have procedures/training in place to ensure the cases never touch the floor or other unclean surface and they are properly palletized and wrapped before storage.

 

When I first came onboard here, I also struggled between the 'eeww' factor and the 'green' factor, but given it is secondary packaging, which is always fully lined with new liners, we have continued this practice and gained our SQF certification.

 

However, the scenario from deterio, does not have the internal controls on how this secondary packaging is handled from when the case was 'new'.

So IMO - reusing secondary packaging with an unknown 'history' isn't a good idea from a food safe or regulatory perspective.

Just have no idea what contamination could be transferred from the case onto the employees hands or other surface.

 

Just my 2 cents...

[johnstuck]

Using custom rigid boxes for shipping is a great idea to be eco-friendly, but before doing it, you need to make sure it's allowed under NSF and GMP guidelines. While there's no specific rule against reusing plain cardboard boxes, using ones with printed labels might not be okay. To be safe, stick to plain boxes without labels for shipping out finished products.