6 replies to this topic

[eastcoastmcm]

Hello! Long time lurker, first time poster :)

 

We recently got a nonconformity for ISO 22002-1:2009 about preprinted bag waste. The finding was for not having a destruction policy for preprinted bag. I am rewriting the policy but need some guidance. 

 

We are a seasoned nut manufacturer. During production our bags can be over/under weight. If they are not within weight range, we open the bag and repack the product in a new bag. The opened bag is considered waste and not reusable. My question is does 7.3 apply to this situation or can we resume to throwing it away as we have been doing? 

 

I have talked with several contractors about waste disposal for preprinted items and it financially is not viable for the company to destroy product regularly in the above scenario. Apx $2k-$5K/year for certified production destruction.

 

I appreciate any recommendations on how to proceed with waste of labelled materials.

 

~M

 

 

 

7.3 Waste Management and Removal                                                                                                                

Provision shall be made for the segregation, storage and removal of waste. 

Accumulation of waste shall not be allowed in food handling or storage areas.  Removal frequencies shall be managed to avoid accumulations, with a minimum daily removal. 

Labeled materials, products or printed packaging designated as waste shall be disfigured or destroyed to ensure that trademarks cannot be reused.  Removal and destruction shall be carried out by approved disposal contractors.  The organization shall retain records of destruction.       

 

[825tzy09]

Hi, MHidalgo.

 

Yep, I think it is. With the cost above, you may try to weigh pros and cons and see if the amount mentioned is reasonable.

 

In case the "waste" bag is mishandled and use for pilferage (food defense), then you are potentially looking for a bigger and more costly problem. From where I am and having observed some small companies with manageable waste, they hire someone to shred by scissor or by paper shredder.

 

However, ultimately, if the waste is significant, then focusing on the reduction of waste generation is much more important. 

 

BR

[hello.fizz]

We have some branded waste from a similar process. The bag is very obviously torn/defaced and we place it in a waste bin with a liner, then when the bin is full (with other rubbish also) it is taken outside. The outside bin is emptied by our waste contractor every 1-2 days and is not accessible to the public. We have assessed this as being a suitable way to dispose of branded packaging as the risk that it can be accessed is low, and if it was accessed while the bin is unlocked we can see it from the office and CCTV. 

[Scampi]

Just cut the bags when you're repacking them into new-put in regular waste 

 

ensure your program has a statement that your waste is picked up and hauled directly to landfill where there is no public access

[Rick Reyes]

Good morning Mhidalgo, I had the same issue, what existed in our waste management policy was not sufficient to cover this issue sufficiently. You are correct that commercial waste management services are cost prohibitive. The goal of this clause is to prevent food fraud, what is your plan to render the packing material unusable by an unscrupulous individual. It can be as simple as melting the ends of the rolls of packing film to that it can not be unwound from the roll and used for unauthorized production of the branded product. For Finish product cases it can be as simple as hosing down the pallets of cases to render the corrugate unusable. Our auditor accepted these types of low cost solutions so long as it is thoroughly documented. 

[jfrey123]

Not proficient in FSSC 22000, but I have to believe an internal destruction process for labels (and in this case the bags to which they were applied) can be undertaken.  I don't see why something as simple as a cutting the bags in half with a knife, through the label, would not suffice.  Make sure your procedures document the steps to be taken, employees are trained in it, and make a space in your production forms to record the number of destroyed labels (if required by your code).

[Jim E.]

Have you looked into recycling firms?  We do that here with both poly and corrugate and get a credit as we recycle through a manufacturer.