Storing Packaging in Product Boxes

its to avoid confusion. Get some plain plastic buckets for this,

If your risk assessment evidences that where you keep these is safe, the containers are appropriate. If you are storing a bag for the produce in a box for the produce there better not be an issue with or the boxes are not appropriate for the produce to begin with and a risk assessment should easily prove this..

 

iii.Packaging, product, and ingredients shall be kept in appropriate containers as required and off the floor;

 

Why shouldn't food contact packaging be stored in product containers? Is it just to limit the potential for contamination?

 

Example, we package a raw agricultural product in carton boxes as well as plastic bags, sometimes the employee will store the plastic bags in the boxes during the run.

 

We store and treat our packaging in sanitary conditions as we do our actual product. I understand labels that do not actually touch the food or maintenance food of course but I am not 100% of the packaging.

 

Based on what I pointed out in red, I took that as the cartons are primary packaging for products and the plastic bags are a different form of primary packaging for your products.

1. Your employees can ship bags out with your product that is in cartons. 
2. If your employees think its ok to store the bags inside of those boxes, they will likely start storing pens, paperwork, etc. inside them as well which increases the risk for something else to be sent out on accident. Also any biological or chemical contaminates
3. The product touches the inside of the plastic bags - not the outside. You might be contaminating the cartons with the plastic bags your employees are touching. Probably a minimal risk. 

So yes - its to limit potential contamination. So either keep the plastic bags in their original shipping container on the production floor or like Glenn said - buy a different dedicated secondary container to put them in. (Label that container as well so its not used for multiple tasks and stays 'clean' just for primary packaging materials) 

It might be a good idea to talk with the employees packing and see if they might have a suggestion on a way to hold or dispense the bags? You might be looking at a one time build of sanitizable dispensers that would solve the whole issue. We have had packing station items made for our processes that employees have suggested and we got more efficiency as well as buy in since the employees made the suggestions and management listened and acted. That kind of goodwill is priceless.