Material intended for recycling

Hi,

We are in the process of complying with the BRC-IOP standard and have a question regarding point 5.2.4 of the standard. We thermo form packaging, both food and non food. At the end of the line, we collect leftover (can be PET, PP, PE, ...) on a roll. Currently, we store both food and non food leftovers in wooden pallet boxes in our warehouse. A company picks it up and processes it and it is recycled. We do not re-use or recycle in-house. Would this be acceptable that the materials are stored in those wooden pallet boxes?

Tom

Hi,

We are in the process of complying with the BRC-IOP standard and have a question regarding point 5.2.4 of the standard. We thermo form packaging, both food and non food. At the end of the line, we collect leftover (can be PET, PP, PE, ...) on a roll. Currently, we store both food and non food leftovers in wooden pallet boxes in our warehouse. A company picks it up and processes it and it is recycled. We do not re-use or recycle in-house. Would this be acceptable that the materials are stored in those wooden pallet boxes?

Tom

Hi Tom, Are you asking if it's ok to have wooden pallet boxes in production? If so, it is not desirable, but yes I think it is OK, provided you have a system in place for minimising the risk of contamination from wood splinters and nails etc. from the crates. This could be for example by checking their condition prior to bringing them into production and ensuring they are checked to be always in very good condition. This should be acceptable. Although I would get plastic crates or bags if possible.

By the way welcome to the forums Tom.

Regards,
Simon

Thx Simon.

Well, we have them in the production area for collecting the leftovers.
Since it's wood, it is ofcourse not recommended to use it in production.
But would plastic pallet boxes, for collecting in production and wooden pallet boxes for storing them in the warehouse be more acceptable?
It is kind of confusing since alot of things are recycled and in the daily world they are stored in numerous more dangerous manners then in food grade packaging producing factory's. So the risk is lower in those controled enviremonts.

Hello Tom,

Welcome to this forum.

The use of wooden pallets or wooden boxes is not dessirable as Simon already stated.
But it can be done if you are able to control possible risks.
During storage it is is the same story, if you can prevent cross contamination with fresh packed products, by using designated area’s for example this should be OK.
Basicly identify the risks and take your measures to control them.
Regarding clause 5.2.4, what issue of the standard are you using, this clause is about entry points in issue 2?

Have a nice day, Okido

Must be issue number 3? I would suggest that you insert LARGE bin liners in the wooden crates to hold all the material , and ensure that you mark the boxes / pallets as "FOR RECYCLING".

Kind regards,

Steve

Yes, using issue 3.

Mmm, so it is realy that stringent. If we would get a certificat (from the company collecting the PET) stating that it is treated to get rid of foreign objects. In that case, based on risk analysis, i would end up with no critical point. Would that be acceptable?

I would expect that to be acceptable, due to it going through "further processing" step.

Regards,

Steve

Yes, using issue 3.

Mmm, so it is realy that stringent. If we would get a certificat (from the company collecting the PET) stating that it is treated to get rid of foreign objects. In that case, based on risk analysis, i would end up with no critical point. Would that be acceptable?

Excuse my ignorance, but why would it be a CCP in your process?
From what i can gather you're not the one reprocessing it, so its not in your product.

It could well be a CCP in the future purchaser of this material, but i would have thought that would have been covered off by a specification or a supplier audit?

The only other thing i might add is that if its a product that is susceptible to taints, that the filled containers are stored away from any potential contaminants, and that the liners are sealed to prevent ingress by pests etc.

c x

It's not a CCP and don't intend to make one of it

But if you look at the whole packaging industy, everybody is using wooden pallets.
For now we plan to allow them to be used for raw material, at the beginning of the line and at the end, where the product is packed in boxes.

The whole process is closed, and when we clean after placing a new roll of plastic (which wheighs about a ton) it should cover any possible issue's.

Hi Tom,

But if you look at the whole packaging industy, everybody is using wooden pallets

I now of quite some good examples were packaging suppliers went to plastic pallets, steelboxes or plastic boxes.
We have in use plastic pallets internally in some parts of the production process and ship in with plastic or steel pallets or boxes.
All wood will be replaced!!!
There is the a foodsafety aspect, but there is also an efficiency aspect, wooden pallets make the workplace dirty and this has to be cleaned, this problem is reduced with plastic and steel.


Have a nice day, Okido

For now we plan to allow them to be used for raw material, at the beginning of the line and at the end, where the product is packed in boxes.

The whole process is closed, and when we clean after placing a new roll of plastic (which wheighs about a ton) it should cover any possible issue's.

It sounds sensible Tom. At these parts of the process the product is less exposed and where wood cannot be avoided just take care. Nobody will shoot you.

regards,
Simon

For now we plan to allow them to be used for raw material, at the beginning of the line and at the end, where the product is packed in boxes.

The whole process is closed, and when we clean after placing a new roll of plastic (which wheighs about a ton) it should cover any possible issue's.

It sounds sensible Tom. At these parts of the process the product is less exposed and where wood cannot be avoided just take care. Nobody will shoot you.

regards,
Simon

Thanks Simon