What are the rules surrounding staples in tertiary packaging?

Hi all, 

What are the rules surrounding staples in tertiary packaging? 

We currently use cardboard surrounds to protect our pallets -  the pallet is first stacked and shrouded before the surround is placed around it, it is then wrapped.

The surrounds contain staples - I'm aware this isn't acceptable around open product areas. 

We store them with the rest of our packaging in a warehouse, and they are only used at the end of packing lines in the production areas. It's also a fully enclosed process. 

Would we be liable for a non conformance for using these? I'm particularly concerned for clause 4.9.2.2.

Any help would be greatly appreciated. 

If it's all enclosed, I don't see why you would receive a non-conformance.

Better to avoid. I have not seen anything with staples. Have your customers never said anything about it? 

Not much different than nails in the pallet at that point. 

Just make sure you have a plan for separating those materials in the event of palletized goods needing to be reworked.

Hi R.H@KB,

:welcome:

Welcome to the IFSQN forums.

BRCGS Global Standard for Food Safety Issue 9 clause 4.9.2.2 states:

The purchase of ingredients and packaging which use staples or other foreign-body hazards as part of the packaging materials shall be avoided.

Staples, paper clips and drawing pins shall not be used in open product areas.

Where staples or other items are present as packaging materials or closures, appropriate precautions shall be taken to minimise the risk of product contamination.

Staples in primary packaging is obviously a definite no, no. I think this clause stems from a long time ago when staples were used to seal bags of ingredients and as such, posed a major risk of contamination when debagging/deboxing.

Clearly staples are best avoided, so secondary packaging also tends to be folded & clipped or glued these days.

For your tertiary packaging, I would ask the question whether they could be supplied glued but I still think the packaging with staples is acceptable to use in a warehouse where the product is already enclosed.

There are a few areas where you could dot the i’s and cross the t’s:

A quick risk assessment of the potential for product contamination (including when de-palletised by the customer)

A check if the staples would be removed by your foreign body detection equipment.

Inspections to ensure the packaging is acceptable and the staples are not loose.

Appropriate storage of the packaging, such as wrapped and at the bottom of the racking, so that if a staple fell out it could not fall onto something which would be used in the production area.

Kind regards,

Tony

We actually have a customer (a major retailer) that insists we use wooden boxes with staples to pack our oysters in. Granted there is an opague liner that is placed into the box and the oysters into this.

This is in, or near, open product areas.

I had to risk access the liklihood of the potential contamination for all other products.