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Primary Packaging Food Grade Composition Requirements

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Dan E

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Posted 30 December 2021 - 11:34 PM

Greetings,

 

I operate a rice processing facility and we are in the process of obtaining BRC 8 certification, planning for the audit next year.

 

We recently started using a zip-tie style bag closure for one of our products. Seeing as this does not contact product (the tie is wrapped around the open end of a poly bag after filling) I am wondering what evidence I need to have to approve this item for use.

 

Per BRC, it constitutes part of the primary packaging of the unit of sale (from the standard: 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)), so I would imagine that I need to ensure there are not any potential issues with chemical migration or that the material is food grade, etc. The problem is, I am not sure what the expectation is for materials that are not expected to contact the food. This does not seem to fit the "direct" or "indirect" food contact categories.

 

Regards,

Daniel

 

 



Evans X.

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Posted 31 December 2021 - 10:39 AM

Greetings Daniel,

 

In chemical migration analysis the whole packaging as it is seen and sold on the shelves is under testing, not just parts of it (the whole packaging will be used in the simulation), so the result includes the zip-tie.

Also if it is possible your zip-tie provider could include an MSDS or an analysis if he performs one for chemical migration.

 

Regards!



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Dan E

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Posted 07 January 2022 - 03:26 PM

Greetings Daniel,

 

In chemical migration analysis the whole packaging as it is seen and sold on the shelves is under testing, not just parts of it (the whole packaging will be used in the simulation), so the result includes the zip-tie.

Also if it is possible your zip-tie provider could include an MSDS or an analysis if he performs one for chemical migration.

 

Regards!

 

Evans,

 

Thank you for the response! Do you know about how I might go about getting chemical migration testing done? From what I have seen it is not typical practice in the zip-tie industry to have it conducted on their products, and I think other bag closures that are typically made for the food industry (e.g. bread bag clips) would not be a sufficiently strong closure for our use.

 

Regards,

Daniel



pHruit

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Posted 07 January 2022 - 05:05 PM

BRC has got a bit carried away with the "primary packaging" thing, IMO.

 

If it isn't food contact then there shouldn't be any need to provide evidence of food-contact suitability/migration testing, and it's certainly not something I've been asked about for the packaging we use that is considered "primary" but is not food contact.

Generally I've found that auditors accept approval of the item based on the existence of a specification - even if it isn't the most comprehensive, as long as it covers the relevant bits for the actual use of the product.

 

You will also need to think about approval of the supplier of the zipties. Hopefully you can construct a position that they are low-risk and can therefore be assessed via questionnaire, but keep in mind that if the supplier isn't certified to one of the GFSI-benchmarked standards then you will be expected to have evidence of traceability exercises for clause 3.5.1.6, and you may also need to look at clause 3.5.1.5. Both of these can be challenging as they're potentially rather alien requirements to business who don't do large volumes into BRC-certified sites. In my experience it's worth giving your supplier a call to explain what and why you need this info, as sending a traceability request of the sort that you might normally do for a food ingredients supplier may just confuse them, and the bit about the identity of the actual manufacturer (if it isn't your supplier) is likely to be met with a "that's confidential information" response, so some discussion and perhaps an agreement that you won't approach the actual manufacturer might be needed.



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Dan E

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Posted 07 January 2022 - 05:22 PM

BRC has got a bit carried away with the "primary packaging" thing, IMO.

 

If it isn't food contact then there shouldn't be any need to provide evidence of food-contact suitability/migration testing, and it's certainly not something I've been asked about for the packaging we use that is considered "primary" but is not food contact.

Generally I've found that auditors accept approval of the item based on the existence of a specification - even if it isn't the most comprehensive, as long as it covers the relevant bits for the actual use of the product.

 

You will also need to think about approval of the supplier of the zipties. Hopefully you can construct a position that they are low-risk and can therefore be assessed via questionnaire, but keep in mind that if the supplier isn't certified to one of the GFSI-benchmarked standards then you will be expected to have evidence of traceability exercises for clause 3.5.1.6, and you may also need to look at clause 3.5.1.5. Both of these can be challenging as they're potentially rather alien requirements to business who don't do large volumes into BRC-certified sites. In my experience it's worth giving your supplier a call to explain what and why you need this info, as sending a traceability request of the sort that you might normally do for a food ingredients supplier may just confuse them, and the bit about the identity of the actual manufacturer (if it isn't your supplier) is likely to be met with a "that's confidential information" response, so some discussion and perhaps an agreement that you won't approach the actual manufacturer might be needed.

 

pHruit,

 

I agree completely. It does seem to be a stretch to require food contact suitability in items that are not supposed to touch the food. I am glad to hear that a specification has been suitable in your experience, hopefully my auditor will agree!

 

As far as our supplier approval goes, the supplier is low risk and willing to work with us on the questionnaire - thank goodness! Good to know about the confidentiality issue, I will keep that in mind should the issue come up.

 

Regards,

Daniel





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