Certification of suppliers for a three layer film structure for food products

My question is regarding a request made by our IMS auditor.

Our Structure is three layers from three production plants. .

Plant 1 produces the outer layer. (Not IMS certified)

Plant 2 produces the middle layer and completes final assembly. (IMS certified plant)

Plant 3 Produces the inner food contact layer. (IMS certified plant)

Our auditor is requesting the plant 1 also be IMS certified because during the winding process, that layer comes into contact with the food contact layer.

This is all produced under Appendix J for single service containers.

Greetings Jchris,

My opinion (and from some experience) you don't need to go through certification to prove that the outer layer is safe for use. You only need to prove that it is safe for use through tests for material migration and microbiological contamination at the end product. If these come back negative then why get in the process of certification and more so when these are being handled by the same company. If you want to take it a step further you could place all this under the supplier evaluation process of the plant that does the final assembly, set the criteria of acceptance, provide documentation and thats it. For a step further you could even do microbiological tests with food that is being packed in these packaging and compare results.

Regards.

I don't know how an auditor can be requesting that plant 1 be certified a standard, that's you as the customer that makes that decision, it's your requirement, not the auditors. 

How you choose your suppliers/manufacturers is your choice. However the rationale behind how/why you use and have approved that manufacturer needs to available.  As MIFSQN noted, you need evidence that the film layer complies to your specifications, is food safe and meets the relevant standards as well as your requirements.

Your manufacturer should be able to provide you with all the required supporting documentation to show that the packaging meets the requirements for direct food contact. You may have also audited the plant and have put in place your own specific requirements for the packaging film. We have a preference for our vendors to be GFSI certified, if not, we require a minimum of HACCP, we don't make our vendors get GFSI certification (we'd like that they do.) As long as they have HACCP and can provide evidence for the food safety aspects of their packaging that is all that is required.

When we get audited by our certifier and customers, they usually ask to see the packaging food safety compliance and that the vendor has a quality certification in place that our procedure states that they must have,nothing more, nothing less.