4 replies to this topic

[C.Giauque]

Hello IFSQN,

 

I work in Food Safety at a chocolate manufacturing company in the United States. We recently completed a surveillance audit last month, and I am currently addressing a non-conformance under clause 3.5.1.2. This non-conformance was issued because we lack a completed supplier approval questionnaire for one of our packaging suppliers—and, in fact, we currently don’t have these questionnaires on file for any of our packaging suppliers.

 

Instead, we’ve been using product specifications and letters of guarantee from these suppliers as part of our approval process. My understanding has been that, in the U.S., most packaging suppliers do not typically hold GFSI-benchmarked certifications let alone maintain HACCP plans, along with some of the other documentation a supplier approval questionnaire would require. I’m finding it challenging to determine how to best resolve this non-conformance, particularly since most of our packaging suppliers likely do not meet the same approval criteria as our suppliers of raw materials.

 

Any insights would be helpful.

 

[nwilson]

SQF'er here, if a food contact packaging is being supplied the below list is applicable for us and has suited me well throughout the years.  So in short yes we require a questionnaire as there needs to be some way of assessing their level of food safety.  We send the same questionnaire we would send a raw material supplier there are sections that are applicable and some that are not to a packaging supplier.  Corrugate suppliers are bit looser as this is more supply chain driven with a contract, letter of guarantee, general spec on the box. 

 

Also get a Certificate of Conformance for each lot food contact packaging.  

1. Current product specifications include: 
   • storage conditions,
   • country of origin,
   • lot code explanation,
   • BPA Free Statement
   • PFAS Free Statement
2. Letter of Guarantee that your product meets all applicable food regulations outlined by the U.S. Food and Drug Administration in the Federal Food, Drug, and Cosmetic Act (FD&C Act), & Bioterrorism Act of 2002 Statement
3. GFSI Food Safety Audit (Certificate and Corrective Actions)
   • If not GFSI Certified please complete attached Supplier Food Safety Questionnaire.
   • If GFSI Certified please complete the Supplier Information page #1 of the Supplier Food Safety Questionnaire ONLY. 
4. California Prop 65 Statement
5. California Transparency in Supply Chains statement
6. Certificate of Liability Insurance

[jfrey123]

 

Instead, we’ve been using product specifications and letters of guarantee from these suppliers as part of our approval process. My understanding has been that, in the U.S., most packaging suppliers do not typically hold GFSI-benchmarked certifications let alone maintain HACCP plans, along with some of the other documentation a supplier approval questionnaire would require. I’m finding it challenging to determine how to best resolve this non-conformance, particularly since most of our packaging suppliers likely do not meet the same approval criteria as our suppliers of raw materials.

 

Any insights would be helpful.

 

 

Two things I'm noticing with my bolded parts of your statement:  Firstly, a food contact packaging manufacturer absolutely should have a HACCP/Food Safety Plan.  And many do actually hold GFSI certs for their processes, with at least as many others operating under some sort of food based third party audit certification (NSF and ISO certs are common amongst my food contact packaging guys).  Secondly, you're assuming your current vendors don't meet, but as part of your corrective and preventative action, here's a chance to update your records and ask each of those vendors.

 

Your criteria for approving a food contact packaging manufacturer probably should be updated if you're looking at them exactly like your raw material/food suppliers.  They're not the same type of commodity, but you do want to ensure the packaging they're providing to you meets safety standards.  Updating your program/forms to reflect a food packaging type is one way to go about self-certifying a non-GFSI package manufacturer.  We don't hold secondary packaging manufacturers to the same standards, a LOG, spec, and insurance cert are about as far as I go for them.  But for our food contact packaging, we absolutely are chasing down full profiles, GFSI certs (or any audit certs we can review), basically the same list I saw above from nwilson. 

[C.Giauque]

Two things I'm noticing with my bolded parts of your statement:  Firstly, a food contact packaging manufacturer absolutely should have a HACCP/Food Safety Plan.  And many do actually hold GFSI certs for their processes, with at least as many others operating under some sort of food based third party audit certification (NSF and ISO certs are common amongst my food contact packaging guys).  Secondly, you're assuming your current vendors don't meet, but as part of your corrective and preventative action, here's a chance to update your records and ask each of those vendors.

 

Your criteria for approving a food contact packaging manufacturer probably should be updated if you're looking at them exactly like your raw material/food suppliers.  They're not the same type of commodity, but you do want to ensure the packaging they're providing to you meets safety standards.  Updating your program/forms to reflect a food packaging type is one way to go about self-certifying a non-GFSI package manufacturer.  We don't hold secondary packaging manufacturers to the same standards, a LOG, spec, and insurance cert are about as far as I go for them.  But for our food contact packaging, we absolutely are chasing down full profiles, GFSI certs (or any audit certs we can review), basically the same list I saw above from nwilson. 

Jfrey,

 

Thank you for your response and the insights included.

 

I would like to clarify that we are a BRC certified facility.

 

If I am understanding these responses correctly I am required to treat our primary packaging as if they were raw materials in the supplier approval process since food comes in contact with these packaging materials. This means primary packaging suppliers are to provide us, at a minimum, with the following requirements as per BRC 3.5.1.2:

 

-Product safety

-Product security

-Food defense

-Product authenticity

-Traceability

-HACCP

-cGMPs 

 

We are a company located in rural Ohio and locally source most of our packaging materials. I have been in ongoing discussions with our packaging suppliers about this subject for years and have thoroughly combed through all their procedures and processes, they do not meet all the minimum requirements. It was within my understanding that the FDA does not require packaging/food packaging manufacturers to uphold HACCP plans or even product traceability. The FDA however does require food packaging materials to comply with CFR Title 21 Chapter I, Subchapter B, Parts 174-190. We have always required our packaging suppliers to supply us with a letter of compliance specifying they comply with these requirements along with cGMPs and product specifications to assess product safety, security, and authenticity.

 

Do you suggest we look into different packaging suppliers for all our primary packaging?

 

I believe our biggest hurdle is going to be labels since BRC classifies them as primary packaging as of issue 9. 

Edited by C.Giauque, 12 November 2024 - 07:47 PM.

[Tony-C]

Hi C.Giauque,

 

Getting information from your suppliers is useful but does not mean compliance with BRCGS Global Standard for Food Safety Issue 9 clause 3.5.1.2. This clause requires approval of suppliers of your primary packaging by audit or certification:

 

‘Your approval can be based on:

• Valid certification to the applicable BRCGS Standard or GFSI-benchmarked standard.

or

• Supplier audits, with a scope to include product safety, traceability, HACCP review, the product security and food defence plan, the product authenticity plan and good manufacturing practices

The audit shall ensure that these plans form part of the supplier’s product safety management system and that any resultant actions are implemented.

The supplier audit shall be 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, product security and food

Defence plan, product authenticity, 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.’

 

As they are local, it would seem that you could audit your primary packaging suppliers yourself if you are suitably qualified. An alternative would be to contract out the audits to a suitably competent auditor.

 

Kind regards,

 

Tony