5 replies to this topic

[Dee70]

Hi,

 

I'm currently writing a TACCP document, which needs to include food contact packaging. I've completed the part for the food products but am a little stumped on how to approach the packaging aspect of the risk assessment.

 

The company use little plastic lidded pots to package sweets - this would be the only food contact packaging on-site.

 

Any advice would be greatly appreciated!

 

Thank You 

[GMO]

There are a few main ways I can think of TACCP threats with packaging.  The first is presumably there is some level of tamper evidence afforded by the lid. If that doesn't work you could have undetected contamination by an ideologically motivated attacker in the supply chain.  Examples I've seen where tamper seals fail in this way is where the whole lid including a break off portion was not specified correctly meaning the whole thing could be taken off and replaced without damaging the tamper seal.

 

Secondly think about the incidents back in the 80s (you're probably too young) of attackers contaminating food by planting it back into supermarkets.  That's where a lot of the tamper evidence came in.  If someone had access to the unfilled packaging, through lack of security at your supplier site, they could then fill it with contaminated product, seal it themselves (depending on what kind of lid it is) and put it on shelf.

 

Then there could be their staff contaminating the food contact surfaces themselves if they were disgruntled employees.  How have they considered that threat?  

 

Lastly this is a packaging thing which may or may not apply in your case but on some packaging once, a disgruntled employee changed the date code to say "sh**" instead.  Another in the artwork department made the cute cartoon characters on pack look like they were doing something sordid...     Funny but led to a withdrawal.  OMG I didn't mean it that way... 

[Dee70]

  I saw a similar scenario occur with a code printing machine in Ireland .. they had actually stamped the code on these sandwich skillets but underneath it was the word b*****ks! .. Although it caused absolute chaos .. I couldn't stop laughing! .. and they never did find the culprit I believe.

 

You answered my question .. I did think tamper proof packaging .. although my brain did go towards dodgy non food grade plastic initially and the use of accredited suppliers etc etc 

 

Thanks anyway and for the laugh!

[GMO]

Ah good point!  They could be using dodgy non food grade stuff but that's probably more vulnerability / VACCP than TACCP.

 

No problem.  Anyone who knows me in real life know I have a terrible sense of humour!

[jfrey123]

Out of all the suppliers I work on in my supplier approval role, I think packaging manufacturers are some of the most frustrating.  At least here in the states, many of them don't view making food grade plastics as inherently riskier than making a regular plastic product.  "Here's your spec claiming it's food grade, have a nice day."

 

I think some of the biggest steps would be to document:

• the manufacturer is registered as a food facility (if UK even has that like US Bioterrorism registration), including a building security plan
• an approved supplier program (to make sure they're controlling their side of the supply chain)
• a decent GMP program (because the dual food/non-food manufacturers can be lazy about this)
• some sort of security measure for the secondary packaging (tamper seals, etc)
• a GFSI audit you can review (we know they can be ineffectual, but at least it was an auditor putting eyes on your site)

[Dee70]

I'm Irish so my sense of humour is woven into my DNA 

 

The attitude is very much the same on this side of the pond jfrey123 - trying to obtain documentation from packaging suppliers AND haulier companies is enough to try the patience of a saint. 

 

I devised a risk assessment that covers both TACCP & VACCP just for good measure but I have only covered food contact packaging but I did manage to cover malicious tampering amidst the adulteration and substitution etc