Food Grade Packaging Evidence
Hi All,
I was just wondering how you prove to an auditor that your packaging is actually food grade?
Is there a certificate that I need to seek out?
Not all packaging suppliers are BRC accredited .. quite a lot actually here in the UK are not.. how am I meant to assess this in terms of a risk assessment - send an SAQ requesting documents? (you wait forever with most of them) or even a Supplier Audit? (or both?)
I don't know enough about plastics or glass or cardboard to know where to begin .... :helpplease:
Any advice would be wonderful!
Please be nice .. I am, after all, working indoors on an extremely rare very sunny Saturday afternoon :shades:
Cheers & Thanks
Hi Dee,
You don’t mention which standard you are working to but I assume BRCGS Global Standard Food Safety. If the packaging is regarded as food contact then you will need to audit or they will need to be certified to a GFSI benchmarked standard for packaging.
Looking at Section 3.5 Supplier and Raw Material Approval and Performance Monitoring, requirements for Supplier Approval are in clause 3.5.1.2:
The company shall have a documented supplier approval procedure to ensure that all suppliers of raw materials, including primary packaging, effectively manage risks to raw material quality and safety and are operating effective traceability processes. The approval procedure shall be based on risk and include either one or a combination of:
• a valid certification to the applicable BRC Global Standard or GFSI-benchmarked standard. The scope of
• the certification shall include the raw materials purchased
supplier audits, with a scope to include product safety, traceability, HACCP review and good manufacturing practices, undertaken by an experienced and demonstrably competent product safety auditor. Where the supplier audit is completed by a second or third party, the company shall be able to:
– demonstrate the competency of the auditor
– confirm that the scope of the audit includes product safety, traceability, HACCP review and good manufacturing practices
– obtain and review a copy of the full audit report
or
• where a valid risk-based justification is provided and the supplier is assessed as low risk only, a completed supplier questionnaire may be used for initial approval. The questionnaire shall have a scope that includes product safety, traceability, HACCP review and good manufacturing practices, and it shall have been reviewed and verified by a demonstrably competent person.
Clause 3.5.1.1 requires
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, legality and quality. his shall take into account the potential for:
• allergen 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.
………………….etc.
Interpretation from BRCGS Guidance:
Regarding the chemical contamination risk stated in the requirement above, examples could be contaminants that occur naturally in the environment, those that migrate from packaging materials, or artificial additions in the supply chain (such as pesticides or veterinary medicines).
Sites should also consider the primary packaging materials used as they too are raw materials. There is potential for packaging materials to pose a problem, whether because of contamination, malicious intervention or the use of inappropriate materials.
As well as supplier approval, you will need to have evidence of the suitability of the packaging for the food you are packing. This can include certificates of conformance, certificates of analysis, migration data and statements from the supplier that the packaging is food grade and suitable for the food you are packing.
Section 5.5 is Product Packaging, Clause 5.5.1 sates:
When purchasing or specifying primary packaging, the supplier of packaging materials shall be made aware of any particular characteristics of the food (e.g. high fat content, pH, usage conditions such as microwaving, other packaging used on the product) which may affect packaging suitability. Certificates of conformity or other evidence shall be available for primary packaging to confirm it complies with applicable food safety legislation and is suitable for its intended use.
Interpretation from BRCGS Guidance:
There have been incidences of product recalls which have resulted from a lack of communication between the supplier of the packaging materials and the food manufacturer, typically where a packaging material has been used in extreme product conditions or where packaging not designed for direct food contact has been used (e.g. a plastic liner of a carton is removed or changed to reduce costs).
The company must be able to demonstrate that each item of product packaging meets legal requirements for its use (e.g. compliance with food contact regulations in the country of sale). This may be in the form of specifications, migration data or a certificate of conformity. Where a declaration of conformity is used, any limitations on usage must be stated (e.g. the food types or storage conditions: ambient, chilled or frozen).
The supplier of the packaging must be made aware of the conditions under which the packaging is going to be used, so that the suitability of the packaging materials can be confirmed. This may take the form of a specification provided to the packaging supplier and would include, as appropriate:
• contact with food – direct food contact or, where not used for direct food contact, the nature of the barrier layer
• characteristics of the food – any adverse characteristics of the food which may increase migration of chemicals from the packaging (e.g. high fat content, or low or high product pH)
• conditions of processing (e.g. high-temperature fill, thermal processing in pack, or freezing)
• expected customer usage (e.g. microwave in pack, cooking in pack, or freezing).
……… etc.
Discussions with the provider of packaging materials are imperative to ensure that the right materials in the right configurations are used (e.g. using lower levels of recycled content in a corrugated case for products that are susceptible to chemical migration). Extensive work at the start of the process is incredibly valuable and can prevent costly errors from being made in specifications.
…… etc.
Kind regards,
Tony
Hi All,
I was just wondering how you prove to an auditor that your packaging is actually food grade?
Is there a certificate that I need to seek out?
Not all packaging suppliers are BRC accredited .. quite a lot actually here in the UK are not.. how am I meant to assess this in terms of a risk assessment - send an SAQ requesting documents? (you wait forever with most of them) or even a Supplier Audit? (or both?)
I don't know enough about plastics or glass or cardboard to know where to begin .... :helpplease:
Any advice would be wonderful!
Please be nice .. I am, after all, working indoors on an extremely rare very sunny Saturday afternoon :shades:
Cheers & Thanks
Hi Dee,
Food Packaging not my specific area of expertise but there are many threads on this Forum discussing the designation of "Food Grade". It can get semantically "involved" (eg see 1st of 4 links compiled below). Yr query is also somewhat "general".
Re ^^^(red) - The "short" (trivial?) answer is that you need evidence/data to show that the Packaging is in "Compliance" with "Food Grade" requirements. The terminology "food grade" is almost invariably mentioned within every packaging manufacturer's website although often with no further "qualifications". My interpretation is that in this context "Food Grade" is used somewhat similarly to that applied to the FDA terminology (see 1st example extract lower down) "FDA Compliant" . This idea is reinforced by the slightly cryptic comment I observed here -
Food grade packaging and guidelines
The UK complies with the EU regulations on food contact materials, which are complex. You can request documentation from your contract packer, known as a ‘declaration of compliance [DoC]’ to get assurances that the packaging provided (if they provide it for you) is safe.
The relevance of the "DoC" is explained here -
https://www.business...ntact-materials
2 examples of DoCs are attached -
Declaration of Compliance.pdf 126.11KB 145 downloads
DoC_example_plastic.pdf 993.35KB 131 downloads
A somewhat expanded description of the typical contents of a DoC is also given here -
https://www.complian...tact-materials/
Some further related comments (ie "long(er)" answers) are provided in the links below with a few "interesting" extracts added -.
https://www.industri...d-safe-meanings
(FDA-US)
https://www.highspee...ging-materials/
(Packaging US-EU-GB-GFSI)
https://www.oliverin...ou-need-to-know
(Food Packaging)
https://foodsafetyte...ways-food-safe/
(more US oriented)
eg -
"FDA compliant" means that a material meets all of the FDA's guidelines for safe, direct contact with food. It's essentially an official way of saying a material is "food grade." To be FDA compliant, a material must be able to withstand the environment it will be used in.
https://www.acplasti...or-food-contact
One of the first considerations for safe packaging is making sure the manufacturer is certified to handle food and beverage products. That may seem obvious, but it can’t be overlooked.
3rd link above
There are several third-party certification companies that verify food equipment and/or food contact materials are indeed “food-safe”, including HACCP International, NSF and 3A.
4th link above
I hope the above is a useful introduction. Packaging experts here are only too welcome to expand.
"Sunny" = a comfortable 40degC ?
Normally, a customer will ask you to provide a regulatory statement and LOG that states you follow such and such guidelines. That should be all an auditor needs from you during your audit. You are proving to the auditor that your company is in compliance, not that your suppliers are, but you need to make sure you are doing your due diligence to make sure suppliers are conforming to your standard and what you have in place. We typically get asked to supply a Regulatory statement, LOG and a 3rd party audit report. Sometimes we have a customer come on site and do an audit, so it varies. I also supply a Letter with a brief overview of programs we have in place, such as GMP's, Foreign material control, etc., just to show that we take food safety seriously.
Normally, a customer will ask you to provide a regulatory statement and LOG that states you follow such and such guidelines. That should be all an auditor needs from you during your audit. You are proving to the auditor that your company is in compliance, not that your suppliers are, but you need to make sure you are doing your due diligence to make sure suppliers are conforming to your standard and what you have in place. We typically get asked to supply a Regulatory statement, LOG and a 3rd party audit report. Sometimes we have a customer come on site and do an audit, so it varies. I also supply a Letter with a brief overview of programs we have in place, such as GMP's, Foreign material control, etc., just to show that we take food safety seriously.
Hi Scotty,
Two comments - The LOG is afaik a purely US (and maybe Canada?) invention. I have never met this "Procedure" anywhere else in the World.
IMEX Supplier Approval is a key, fundamental, function within the FS System of a Manufacturer, not an "add-on".
Hi All,
I was just wondering how you prove to an auditor that your packaging is actually food grade?
Is there a certificate that I need to seek out?
Not all packaging suppliers are BRC accredited .. quite a lot actually here in the UK are not.. how am I meant to assess this in terms of a risk assessment - send an SAQ requesting documents? (you wait forever with most of them) or even a Supplier Audit? (or both?)
I don't know enough about plastics or glass or cardboard to know where to begin .... :helpplease:
Any advice would be wonderful!
Please be nice .. I am, after all, working indoors on an extremely rare very sunny Saturday afternoon :shades:
Cheers & Thanks
In a technical term: A proof of food-grade of the products, normally by random sampling and tests (e.g. migration) by an external institute, which then could be resulting to a .DoC (e.g. EU 10/2011 for plastic). In case of Brexit, I have no idea yet.
In a systematic term: A proof for the confidence of that such a supplier would produce consistently food-grade packaging. Supporting information can be a certification of certain standard (BRC, SQF, etc.) or your own (supplier) audit report.
packaging suppliers provide DOC (declaration to conformity) to applicable standards then supplement document is 3rd party testing of the packaging to assure conformity