Reducing Food Safety Risks through Recognized Systems. Thomas Bouraoui -- Exopack Corporate Director of Quality & CI

Transcription

1 Reducing Food Safety Risks through Recognized Systems Thomas Bouraoui -- Exopack Corporate Director of Quality & CI

2 Agenda CPG Expectations FSMA overview GFSI overview The Big 4 GFSI Standards Summary 2/26/2013 2

3 CPG Expectations

4 Necessary mindset If your product touches food at some point in the downstream supply chain, you are a part of the Food Industry. Treat Food Packaging (Human and Pet) with the same food safety rigor as food look at potential risks from design to consumption Adapted from: Food Safety Alliance for Packaging

5 Typical Expectations for Packaging Supplier Approval Supplier survey / risk assessment Site Audit: 3 rd party; perhaps for a GFSI or other Food Safety certification; CPG internally developed audit Typical assessments: GMPs HACCP Supply chain management/approval process Raw material regulatory approvals RSOL/migration testing Adapted from: Food Safety Alliance for Packaging

6 Food Safety is Still Big News Adapted from: Food Safety Alliance for Packaging

7 Top Food Safety Related Issues Associated with Packaging Undeclared /Unlabeled Allergens Mixed labeled packaging materials (e.g., labels, cartons, film, lids, cups, ) Printing Errors Chemical Migration Migration into product or package (e.g., film, pallets, ink ) May be Perceived food safety issues ODORS, TASTE Adapted from: Food Safety Alliance for Packaging

8 U.S. and Canadian Food Recalls U.S Canada E. coli Listeria Salmonella Foreign Material Source: Food Industry Report Vol. 24 No. 4 April 2012 Undeclared Ingred/ ALLERGENS

9 Pro-active packaging suppliers prevent mixed labeling A priority concern: misbranding issue if allergens = safety issue Finishing Line Clearance MAJOR STEPS KEY POINTS Step # verify new WO jacket samp le to new WO jumbo 1.2 signoff on Startup Checklist (copy verified) 1.3 verify Roll History ticket info against Splice different WO's at unwind 1.4 load jumbo onto unwind 1.5 check off jumbo roll # on previous opertn 1.6 splice current WO & new WO w 2" brown tape Step # jog and stop sp lice just before rewind nip A pro-active approach: assess risks human and electronic controls VERIFY Advance new WO thru machine Remove all of previous WO from machine area Step # sign off on checklist Sign off Line Clearance 2.2 remove current slit rolls; splice stays on m'ce 2.3 p lace core tags onto all rolls (roll doc & finished) 2.4 bag rolls (if required) 2.5 confirm p ap erwork (FG slit roll tally sheet, roll doc rolls w sticker explaining defect & WO) Step # complete all docs in job jacket + place on pallet 3.2 current job jacket on roll doc pallet if applic. 3.3 move all current FG material to pallet wrapping 3.4 wrap p allet of roll doc material before moving to roll doc area 3.5 do not mix rolls on pallets Step # p lace new cores onto rewind arms or shafts 4.2 jog web until sp lice p asses core 4.3 cut off tail with sp lice and disp ose of it Remove splice and wind onto 4.4 attach new WO to core per wind instructions new cores Step # conduct required quality checks and paperwork 6.2 start machine and begin production Begin production of new WO

10 Packaging Suppliers must appreciate Controls need to be in place at the packaging manufacturer AND the food processor HACCP Programs help identify places where controls can be implemented to address hazards The HACCP approach is a proven food safety program accepted worldwide - the ultimate goals: Protect consumers (Human and Animal) Prevent / Eliminate Recalls Adapted from: Food Safety Alliance for Packaging

11 The Food Safety Modernization Act

12 FSMA signed into U.S. law Jan. 4, 2011 most sweeping overhaul since the Great Depression vastly broadens FDA power main areas of enhancements: Preventive controls - from response to prevention (holds producer accountable for preventing contamination) Inspection and compliance Imported Food Safety Response - recalls Everyone in the chain must do their part. 2/26/

13 Where FSMA is headed. and what does it mean to packaging suppliers? New rules may take several years to go into effect Trend: though FDA does NOT require HACCP for packaging suppliers; customers increasingly require it! Preventive focus Proactive bias 2/26/

14 Proactively prepare until rules finalize don t fret the review process see the big picture common-sense prevails implement proven concepts and systems Do the things you know are right up-date and fine-tune when rules go into effect! 2/26/

15 FSMA is predominantly HACCP related Be practical: build upon existing GMPs and HACCP efforts! Big Picture: It s all about taking risk out of our operations through v recognized Food Safety Management Systems 2/26/2013 Source: Diagram adapted from Certified HACCP Auditor Handbook 15

16 5 Preliminary Tasks 7 HACCP Principles Follow the HACCP methodology HACCP requirement 1. Assemble the HACCP team 2. Describe each product type and distribution 3. Describe the intended use and customers 4. Develop flow diagram that describes process for each product 5. Verify the accuracy of the flow diagram GMPs / PRPs CCPs HACCP requirement 1. Conduct hazard analysis 2. Identify CCPs 3. Establish critical limits for each CCP 4. Establish monitoring procedures for each CCP 5. Establish corrective actions 6. Establish verification procedures 7 Establish record keeping /documentation procedures

17 Primary Pitfalls in HACCP Plans food safety policy, objectives, and HACCP plan goals and responsibilities not adequately defined or communicated. PRP s not effective, and/or 5 preliminary steps and/or the 7 principles not well executed. ineffective ownership and communication across the facility (trying to do it all yourself). does not accurately reflect the actual products, processes, hazards, and controls.

18 Don t overlook keys to success Hygienic Design Facility - equipment - workplace cleanable and accessible surfaces cleaning practices - tools & supplies Education and Training internal/external 100% involvement accountability Partner with Suppliers and Food Customers concerns / solutions / validation events, technical committees customers make us better! Certification (trend: CPGs driving upstream) 2/26/

19 Global Food Safety Initiative (GFSI)

20 Global Food Safety Initiative Vision: Safe Food for Consumers Everywhere Mission: Driving continuous improvement in food safety to strengthen consumer confidence worldwide 650+ members - offices on 3 continents - retail and manufacturing 2/26/2013 Source: adapted from GFSI website 20

21 How does GFSI work? benchmarks existing food safety schemes recognizes schemes which are equivalent to the Guidance Document requirements Key intents: consumer trust & supply chain safety harmonization (reduced duplication) competition (improvement of schemes) comparable audits w/ equivalent results a wishful thought once certified, accepted everywhere

22 Growth of GFSI acceptance At forefront in 2007: these retailers announce uniform acceptance of GFSI benchmarked standards: Companies now accepting or requiring GFSI recognized schemes (retailers and manufacturers):

23 The Big 4 GFSI Schemes

24 The Big 4 GFSI recognized Standards North American Packaging Supplier perspective IFS PACsecure ( FSSC ( BRC Food ( SQF ( 2/26/ Currently seeking recognition

25 BRC British Retail Consortium categories high hygiene risk (direct food contact, or hygiene sensitive) low hygiene risk (pkg for consumer products, non-contact food pkg) no separate document review increased emphasis on factory floor considers risk assessment based justifications packaging focused standard -- global recognition most prescriptive broad coverage (product safety, quality, compliance) 2/26/

26 FSSC Food Safety Systems Certification Defined in the two standards: ISO contains requirements for the Food Safety Mgmt System PAS 223 contains requirements for PRPs PAS 223 outlines 15 PRPs associated w packaging evaluates food safety only; not quality Recertify every 3 yrs. 2/26/

27 SQF -- Safe Quality Foods SQF has Two Codes SQF 1000 = Primary Producers SQF 2000 = Food Processors (and Packaging) SQF has Three Levels of Certification Level 1 = Food Safety Fundamentals (GMPs, PRPs) Level 2 = Food Safety Plan (HACCP) Level 3 = Food Quality Plan (HACCP driven) Requires trained SQF Practitioner on-site Changes are made for compliance and CI: GFSI Guidance (currently Issue 6) SQF (Edition 7) 2/26/

28 Typical Audit Problems (example: SQF) poor understanding of Verification vs. Validation verification (are we doing what we say we re doing?) validation (is it working?..) insufficient understanding of Food Safety Process employees WILL get questioned should have access to and be trained on and work to standards recall teams have not drilled suppliers not approved /monitored / reviewed 2/26/

29 IFS PACsecure recently joined forces --- seeking GFSI recognition developed by packaging suppliers and food industry Codex principles non-prescriptive, risk-based excellent program with good tools and training provides production-floor guidance on-line training modules approved by the Food Safety Alliance for Packaging (FSAP) in the U.S. 2/26/

30 Summary

31 HACCP is core - - regardless of scheme Materials and Processes Hazard Types Biological Chemical Physical

32 Remember. understand downstream uses understand the distribution and ownership inform your suppliers; hold them accountable control what you can in your process manage risks with strong PRPs or with CCPs systematically address Biological, Chemical, & Physical risks need competent workforce re: material hazards process hazards monitor your control points Adapted from: Food Safety Alliance for Packaging

33 Everyone benefits from Food Safety secures public health and peace of mind increases exporting opportunities more conscientious workforce a clean/hygienic workplace is more efficient - morale protects reputation / brand equity reduces business risk smoother customer relationships; enables growth key trust factor just like any safety issue

34 Helpful Resources Food Safety Alliance for Packaging HACCP Models List of Service Providers -- training and other resources available (e.g., IFS PACsecure, GFSI Certification) Adapted from: Food Safety Alliance for Packaging

35 Blank area for graphics I d like to thank members from the following organizations as well as all contributors to the Food Safety Alliance for Packaging for providing content and conversation to support this presentation: 2/26/