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BRC Packaging 3.9 - Managment of subcontracted activities and outsouced processes

Started by , Nov 17 2020 04:25 PM
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Hi,

 

There are "two different printing cases" in my company. Speaking of concrete cases:
 
1) We buy film reels which we then have printed by an external company. When the printed material comes back to our site we convert the film reels into bags.
 
In this case it is a subcontracted process, I have to comply with requirement 3.9.4: 
"Where any process steps in the manufacture of the packaging materials are subcontracted or outsourced, final release of the product shall remain the responsibility of the site. Controls shall be in place for checks on finished work to ensure product safety and quality meets specification prior to dispatch to the final customer."
 
Can anybody help me to define what kind of controls I have to make to check the printing on finished work?
 
 
2) Then we have film reels or bags that are already printed from our supplier. We do not do any manipulation. It is a traded good. Do I have to do print control in this case ?
 
Thanks in advance!!!  :smile:
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Hi Carolina

 

I work for a packing company and our controls are related to check against our specifications. Make sure art work is correct, correct materials, size, etc.

 

Is your company a co-packer? if is so, checks that you are doing over final product (pack product)?

Hi Carolina

 

I work for a packing company and our controls are related to check against our specifications. Make sure art work is correct, correct materials, size, etc.

 

Is your company a co-packer? if is so, checks that you are doing over final product (pack product)?

 

Hello,

 

No, we are not a co-packer. We produce and comercialize packaging material for direct contact with food. 

Hi Carolina

 

We are a printing and packaging co as well. 

 

Case 1: if you are procuring the raw materials, then you do incoming inspection of reels. When you send to print outside it is an subcontracted process. This company will need to be audited by yourself and should have a GFSI certificate.

In your HARA you will include the subcontracted process step. your co needs to have a contract and SLA with the subcontractor outlining your production requirements, inspection criteria, delivery , and C/A sop.   Your co. will have to  verify their quality inspections. You should ask your supplier for an process flow and a FMEA of their process to verify quality inspections. 

You should receive these printed reels back with a COC/ COA. You should do incoming inspections for printed goods: register, colour, text, position etc. 

 

As for sec 5.1, you will outline your process on initiating a new product, i.e. artwork, subcontracting and specifications. 

 

 Case 2: its a traded good as you mentioned. However , all the above steps still apply. 

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