Hi Dee,
You don’t mention which standard you are working to but I assume BRCGS Global Standard Food Safety. If the packaging is regarded as food contact then you will need to audit or they will need to be certified to a GFSI benchmarked standard for packaging.
Looking at Section 3.5 Supplier and Raw Material Approval and Performance Monitoring, requirements for Supplier Approval are in clause 3.5.1.2:
The company shall have a documented supplier approval procedure to ensure that all suppliers of raw materials, including primary packaging, effectively manage risks to raw material quality and safety and are operating effective traceability processes. The approval procedure shall be based on risk and include either one or a combination of:
• a valid certification to the applicable BRC Global Standard or GFSI-benchmarked standard. The scope of
• the certification shall include the raw materials purchased
supplier audits, with a scope to include product safety, traceability, HACCP review and good manufacturing practices, undertaken by an experienced and demonstrably competent product safety auditor. Where the supplier audit is completed by a second or third party, the company shall be able to:
– demonstrate the competency of the auditor
– confirm that the scope of the audit includes product safety, traceability, HACCP review and good manufacturing practices
– obtain and review a copy of the full audit report
or
• where a valid risk-based justification is provided and the supplier is assessed as low risk only, a completed supplier questionnaire may be used for initial approval. The questionnaire shall have a scope that includes product safety, traceability, HACCP review and good manufacturing practices, and it shall have been reviewed and verified by a demonstrably competent person.
Clause 3.5.1.1 requires
The company shall undertake a documented risk assessment of each raw material or group of raw materials including primary packaging to identify potential risks to product safety, legality and quality. his shall take into account the potential for:
• allergen contamination
• foreign-body risks
• microbiological contamination
• chemical contamination
• variety or species cross-contamination
• substitution or fraud (see clause 5.4.2)
• any risks associated with raw materials which are subject to legislative control.
………………….etc.
Interpretation from BRCGS Guidance:
Regarding the chemical contamination risk stated in the requirement above, examples could be contaminants that occur naturally in the environment, those that migrate from packaging materials, or artificial additions in the supply chain (such as pesticides or veterinary medicines).
Sites should also consider the primary packaging materials used as they too are raw materials. There is potential for packaging materials to pose a problem, whether because of contamination, malicious intervention or the use of inappropriate materials.
As well as supplier approval, you will need to have evidence of the suitability of the packaging for the food you are packing. This can include certificates of conformance, certificates of analysis, migration data and statements from the supplier that the packaging is food grade and suitable for the food you are packing.
Section 5.5 is Product Packaging, Clause 5.5.1 sates:
When purchasing or specifying primary packaging, the supplier of packaging materials shall be made aware of any particular characteristics of the food (e.g. high fat content, pH, usage conditions such as microwaving, other packaging used on the product) which may affect packaging suitability. Certificates of conformity or other evidence shall be available for primary packaging to confirm it complies with applicable food safety legislation and is suitable for its intended use.
Interpretation from BRCGS Guidance:
There have been incidences of product recalls which have resulted from a lack of communication between the supplier of the packaging materials and the food manufacturer, typically where a packaging material has been used in extreme product conditions or where packaging not designed for direct food contact has been used (e.g. a plastic liner of a carton is removed or changed to reduce costs).
The company must be able to demonstrate that each item of product packaging meets legal requirements for its use (e.g. compliance with food contact regulations in the country of sale). This may be in the form of specifications, migration data or a certificate of conformity. Where a declaration of conformity is used, any limitations on usage must be stated (e.g. the food types or storage conditions: ambient, chilled or frozen).
The supplier of the packaging must be made aware of the conditions under which the packaging is going to be used, so that the suitability of the packaging materials can be confirmed. This may take the form of a specification provided to the packaging supplier and would include, as appropriate:
• contact with food – direct food contact or, where not used for direct food contact, the nature of the barrier layer
• characteristics of the food – any adverse characteristics of the food which may increase migration of chemicals from the packaging (e.g. high fat content, or low or high product pH)
• conditions of processing (e.g. high-temperature fill, thermal processing in pack, or freezing)
• expected customer usage (e.g. microwave in pack, cooking in pack, or freezing).
……… etc.
Discussions with the provider of packaging materials are imperative to ensure that the right materials in the right configurations are used (e.g. using lower levels of recycled content in a corrugated case for products that are susceptible to chemical migration). Extensive work at the start of the process is incredibly valuable and can prevent costly errors from being made in specifications.
…… etc.
Kind regards,
Tony
