11 replies to this topic

[NipunRRSL]

why do FSSC 22000 and BRCGS Issue 9 not require vulnerability assessments for primary packaging materials, even though suppliers could engage in fraudulent activities during their production?  Since primary packaging materials directly contact the product, there is a potential risk of fraud that might go unnoticed.

Really appreciate all your ideas in ths regard.

[Dorothy87]

hi :) 

 

BRC issue 9 (food) does. 

 

Section 3.5.1.1

 

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, authenticity, legality and quality. This shall take into account the potential for:

 

• allergens (allergen content and potential 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 or customer requirements.

 

[NipunRRSL]

Hi Dorothy87, 

 

In BRCGS Issue 9, clause 5.4.2 does not address vulnerability assessments for primary packaging, as clarified in the interpretation guide. Clause 3.5.1.1, however, focuses on conducting risk assessments for the acceptance and testing of raw materials assessment?

 

[Dorothy87]

for example : 

 

The packaging vulnerability risk assessment can based on low, medium, and high risk and considers the following risks ;

• Historical evidence scores including substitution fraud or adulteration.
• Nature of material score
• Economic factors score.
• Ease of access score
• Malicious tempering score
• Testing availability score

[NipunRRSL]

But, the interpretation guide clearly states, "This section applies to food raw materials and ingredients; therefore, packaging is not required to be considered under this section."

[Tflex]

I don't have acces to the interpretation guide but I also assumed BRCGS 9 requires food fraud risk assessment for primary packaging.. Can you maybe screenshot this specific section of the interpretation guide?

[AltonBrownFanClub]

@TFlex, I just checked here (USA) in case it was locked in your region.

 

Unfortunately, it is a copyrighted document and not available for download.

If you are a BRC customer, you may be able to view it.

 

Here is a link to the download from BRCGS.

https://www.brcgs.co...deline/p-12227/

[Dorothy87]

I don't have acces to the interpretation guide but I also assumed BRCGS 9 requires food fraud risk assessment for primary packaging.. Can you maybe screenshot this specific section of the interpretation guide?

 

Hi, Unfortunately, this is illegal. 

 

Section 5.4.2 refers to raw materials.

 

Considering 3.5.1.1 I would stick to - authenticity - " 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, authenticity, legality, and quality.

 

3.5.1 "Primary packaging materials are also included in this requirement. Packaging is vital to product integrity in the

packing environment, and during storage and distribution within the supply chain"

[Ishau]

Just thought I'd jump in here and provide some clarification. We will not raise a non-conformance during your audit if you haven't done a vulnerability assessment which includes packaging.

 

Firstly, just to confirm that you are not required to complete a vulnerability assessment on primary packaging materials.

The requirements of clause 5.4.3 only applies to food raw materials. In fact the whole of section 5.4 applies only to food raw materials.

 

However, clause 3.5.1.1 does require your raw material risk assessment to consider substitution or fraud for primary packaging.

You'll also notice a typing error in the Standard here, where it incorrectly refers you to clause 5.4.2 but it should be 5.4.3.

 

So as part of your raw material risk assessment you do need to consider such risks.

It does not need to be the in-depth vulnerability assessment that you are required to do under 5.4.3 - so you don't need to include the mandatory requirements of historical evidence of substitution or adulteration, economic factors which may make adulteration or substitution more attractive, ease of access to raw materials through the supply chain, sophistication of routine testing to identify adulterants and the nature of the raw material.

However you will need to consider vulnerability more generally of those packaging materials. This could be very simple such as just being based on the supplier you are using and the nature of the packaging and whether any claims are made (e.g. recycle content, eco claims etc).

 

The other thing is, for food raw materials you need to review the vulnerability assessment annually, but for primary packaging because it's only done as part of the raw material risk assessment you only need to review this every 3 years.

[NipunRRSL]

Hi Ishau, 

Got the idea. Really appriciate your comment.

 

@Dorothy87, @AltonBrownFanClub, @Tflex,

Thank you so much for the comments.

[ngoran55]

Hello everyone.

 

I have a dilemma regarding the assess of NATURE OF RAW MATERIAL, in field of production flexible packaging materials in extrusion process where is usually used granules as a raw material? 

How can I assess this factor...? :-) 

[NipunRRSL]

Hello everyone.

 

I have a dilemma regarding the assess of NATURE OF RAW MATERIAL, in field of production flexible packaging materials in extrusion process where is usually used granules as a raw material? 

How can I assess this factor...? :-) 

 

AFAIK, Section 5.4.2 of BRCGS Issue 9 applies to food raw materials, not packaging raw materials materials.