SQF Edition 8 Changes to the Food Packaging Manufacturing Code

Transcription

1 SQF Edition 8 Changes to the Food Packaging Manufacturing Code April 2018 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 1

2 Objectives General changes to management of the code Food Fraud Environmental monitoring for packaging manufacturing plants Overview of changes to SQF Code version 8 for Packaging Manufacturing 2 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 2

3 SQF Food Safety Code for Manufacture of Food Packaging Covers the system elements and Good Manufacturing Practices for the manufacture of food packaging. Addresses items that may be used in food manufacturing or food service facilities (e.g. paper towel, napkins, disposable food containers, straws, stirrers) Applicable GDP module is module 13 3 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 3

4 Part A Update - Food Safety Added requirement for all operational, cleaning shifts and preoperational inspections, where applicable Option for corporate audits New mandatory elements Complaint Management (all scopes) Allergen Management (manufacturing, storage and distribution, manufacture of food packaging) Changed corrective actions close out timeframe Minors and Majors- close out in 30 days Removed OIPs as a response 4 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 4

5 Part A Update - Food Safety Unannounced audit protocol remains the same however-- Added protocol for voluntary annual unannounced audit Recognition on the certificate Surveillance audit following suspension is now termed as an on-site visit and is unannounced Withdrawn sites are posted on sqfi.com for 12 months Withdrawn sites are required to wait 12 months before reapplying for certification New section on compliance Re-defined requirements for technical experts Re-designed food sector categories for clearer identification of industry scopes 5 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 5

6 Mfg of Food Packaging Systems Elements Key Changes Food Packaging Manufacturing has its own module 2 System Elements System elements for manufacture of food packaging generally follow manufacturing Clarified the application of the Code is to the manufacture of food packaging Reference to materials to raw materials; reference to ingredients removed Module 13 remains the module for Food Packaging Manufacturing Two major changes that have caused confusion Food Fraud Environmental Monitoring 6 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 6

7 Food Fraud Requirements Food Fraud The methods, responsibility and criteria for identifying the site's vulnerability to food fraud shall be documented, implemented and maintained. The food fraud vulnerability assessment shall include the site's susceptibility to product substitution, mislabeling, dilution, counterfeiting or stolen goods which may adversely impact food safety A food fraud mitigation plan shall be developed and implemented which specifies the methods by which the identified food fraud vulnerabilities shall be controlled The food fraud vulnerability assessment and mitigation plan shall be reviewed and verified at least annually Records of reviews of the food fraud vulnerability assessment and mitigation plan shall be maintained 7 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 7

8 Food Fraud Requirements 2.7 Food Fraud: A collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product, for economic gain. Food Fraud & Food Defense are listed in both the Manufacturing Code and the Quality Code In SQF Manufacturing Code: The site's food fraud vulnerability assessment (refer to ) shall include the site's susceptibility to raw material or ingredient substitution, mislabeling, dilution and counterfeiting which may adversely impact food safety The food fraud mitigation plan (refer to ) shall include methods by which the identified food safety vulnerabilities from ingredients and materials shall be controlled. 8 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 8

9 Food Fraud Requirements 2.7 What is a Food Fraud Vulnerability Assessment? The vulnerability assessment must be documented and identify hazards that may be present in the food because they occur naturally, are unintentionally introduced, or are intentionally introduced for purposes of economic gain, and can be a public health risk if not addressed. The assessment will determine if there are hazards and which need preventive controls. 9 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 9

10 Food Fraud Requirements 2.7 What does this vulnerability assessment look like? No specific requirement in the code. It has to be documented! Can resemble a food safety hazard analysis but in place of bacteria, physical, and chemical hazards, it states fraud potential. Could be a spread sheet that list raw materials and key process steps and asks key questions that will help with your decision in determining food fraud risk. Potential vulnerabilities Use of recycled material when it is supposed to be virgin Counterfeit packages (printing operations) 10 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 10

11 Food Fraud Requirements 2.7 What is a Food Fraud Mitigation Plan? This is a documented control plan to manage the food fraud hazards identified in the vulnerability assessment. The measures the site has developed to manage the risks must be written. For more information on Food Fraud related to SQF and GFSI, visit 11 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 11

12 Environmental Monitoring Edition 8 Requirements for Environmental Monitoring Program (EMP) A risk based environmental monitoring program, for known or expected concerns, shall be in place for all processes in the manufacturing of food packaging. Key words Risk based In place for all processes The responsibility and methods for EMP shall be documented and implemented. This is a written program no different than other prerequisite programs or required procedures. Corrective actions need defined. 12 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 12

13 Environmental Monitoring Edition 8 Requirements An environmental sampling plan and testing schedule, appropriate to the nature of the product, shall be prepared, detailing any applicable pathogen(s), the number of samples to be taken, and the frequency of sampling. Identify pathogen you are testing for Number of samples taken at each sampling Frequency of sampling 13 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 13

14 Environmental Monitoring Edition 8 Requirements Environmental testing results shall be monitored and corrective actions implemented where unsatisfactory trends are observed. Responsible person monitors the results Corrective actions implemented (refer to ) 14 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 14

15 Environmental Monitoring What does your program look like? Based on risk High risk plan model Low risk plan model Remember this is your program so frequency, number of samples, pathogen tested for are defined by you. Should have some scientific or industry input on pathogen you need to look at 15 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 15

16 Manufacturing of Food Packaging Key Changes 2.1 Emphasis on Senior Management: Emphasized site management responsibility for training and communication Stronger language for staff for regulatory responsibility Role in meeting the SQF Food Safety Code New element on change management Require monthly meetings between Senior Management and the SQF practitioner Blackout periods now included in system elements, to allow auditor opportunity to check designated blackout dates Business Continuity Planning is now Crisis Management Planning. More detailed requirements 16 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 16

17 Manufacturing of Food Packaging Key Changes Packaging used for functional effect have specified criteria and referenced in the food safety plan Eliminated reference to shelf life trials; Added requirement for records and validated storage conditions Procedure for certification & approval of artwork used in the print process. Controls include how print run samples are approved by customers, color standards are developed, and changes to artwork are managed Finished product specs include artwork and unitizing requirements and confirmation that packaging product is suitable for intended use by the customer 17 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 17

18 Manufacturing of Food Packaging Key Changes Packaging with product ingredient lists(s), allergens, identification codes, etc., shall be managed in a manner that prevents misprinting Removed reference to validation of packaging material Modified to include Product ingredient lists(s), allergens, identification codes, etc., Removed reference to requirements not applicable to food packaging 18 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 18

19 Manufacturing of Food Packaging Key Changes Significant detail around the food safety plans. New element to require regulatory controls as well as CODEX 17 specific requirements Should have been there as plans needed to meet Codex requirements but now are stated clearly New element on food fraud ( , ) and food defense ( ) plan required for incoming materials 19 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 19

20 Manufacturing of Food Packaging Key Changes HACCP Requirements - Many of these requirements were implied in Edition 7.2 as the plan had to comply with Codex and NACMCF were required to be followed Multi-disciplinary Team Scope developed and documented including start and end points, inputs and outputs Product descriptions need developed for all products Intended use statement includes target consumer groups, potential consumption by risk population, and potential alternate use Specific requirements for flow diagram Hazard assessment is the same Includes inputs such as raw materials, processing aids, steam water, gases, etc. 20 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 20

21 Manufacturing of Food Packaging Key Changes HACCP Requirements- continued Control measures identified and documented for the hazards defined CCP identification has to be documented CCPs have defined critical limits Develop and document procedures to monitor CCPs o Previously only required SOPs and WIs written to cover the scope of certification o This is a shall so procedures need to be written o Training required and this is important also for FSMA plants Deviation procedures shall be developed and documented Review plan annually or whenever changes occur Plan needs verified Regulatory requirements have to be met 21 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 21

22 Manufacturing of Food Packaging Key Changes Approved Supplier Program changes Food Defense requirement as it relates to suppliers and Food fraud elements for raw materials Supplier audit requirements Added that reworked product is processed in a manner that does not contaminate raw materials or food packaging materials New element on the handling of post-consumer recycling Information shall be handled in a manner that prevents mixed up or intermingled product Environmental monitoring added as a requirement 22 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 22

23 Manufacturing of Food Packaging Key Changes Returned product handling On-site personnel requirements for conducting test on finished products Procedures in place for managing and verifying correct printing plates, anilox rollers, cylinders are used during printing Procedures for storing print plates and other print tools and for identifying print errors Procedure for disposal of trademarked material Included recycled material 23 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 23

24 Manufacturing of Food Packaging Key Changes Handling and disposal of sampled materials Regular inspections of site and equipment meet GMP and SQF requirements Maintain records of inspection and corrections Procedures for start-up with approval from an authorized person SQF and Eagle shall be listed as an essential body and notified in food safety incidents of a public nature (recall and regulatory warning letter) 24 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 24

25 Manufacturing of Food Packaging Key Changes Food Defense Plan changes iv Added receipt to this requirement v Added measures to ensure raw materials, WIP, process inputs are held under secure storage and transportation The food defense plan shall be reviewed and challenged at least annually Records of reviews of the food defense plan shall be maintained 25 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 25

26 Manufacturing of Food Packaging Key Changes Allergen Program Requirements i Risk assessment includes printed packaging ii assessment of workplace for allergens for vending machines, lunch rooms vii Allergen changeover for cleaning Program required even if no allergens identified Unintended introduction by supplier, contract manufacturer, service provider, employee and visitor 26 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 26

27 Mfg of Food Packaging Module 13 Key Changes Customized throughout to fit with the manufacture of food packaging more specific as to what areas included Added fit for purpose for floors Dust control methods Specifications for equipment, utensils, protective clothing & purchasing procedures for equipment documented Temporary repairs cleaning and completion Electronic equipment being used on a daily basis shall be calibrated daily by the users. 27 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 27

28 Mfg of Food Packaging Module 13 Key Changes Pest Control changes Changes are really clarifications Identified pest activity does not present a risk of contamination to food products, RM, or packaging Items contaminated by pest - records of disposal & required investigation and resolution ii Record pest sightings and trend the frequency of pest activity to target pesticide application. 28 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 28

29 Mfg of Food Packaging Module 13 Key Changes New element to cleaning and sanitation to protect adjacent production equipment during cleaning if using compressed air hoses Deleted reference to cleaners and sanitizers and replaced with cleaning agents Added that drinking water is permissible New element for training visitors on site hygiene policy iii Back flow prevention iii Water used for hand washing shall be monitored. 29 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 29

30 Mfg of Food Packaging Module 13 Key Changes Air is filtered using an appropriate filter capable of removing dust, oil, moisture and micro-organisms, to avoid cross contamination to package materials Documented storage plan required Use of hazardous chemicals shall be used according to manufacturer s recommendations and SDS Sharps program required Exterior collection and storage bins must be covered. 30 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 30

31 Food Technical Support at EAGLE Questions? EAGLE s Technical Team is available to answer any questions you have about SQF edition 8. Roger Roeth, Executive Technical Officer: roger.roeth@eaglecertificationgroup.com Anne Cooper, Food Technical Manager: anne.cooper@eaglecertificationgroup.com 31 EAGLE Certification Group includes EAGLE Registrations Inc. and EAGLE Food Registrations Inc. 31