Key Changes for the Packaging Industry. Larry Dworkin Director of Government Relations The Packaging Association
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1 Welcome
2 Key Changes for the Packaging Industry Larry Dworkin Director of Government Relations The Packaging Association
3 Agenda Packaging Hazards HACCP Program GFSI Requirements for the Packaging Industry Q&A
4 Did you know Some contaminants may be traceable to packaging Stainless Steel in plastic packaging BSE-TSE Beef derived Mad Cow Disease o Inks & Coatings Biological Hazards o Mould o Pallets, paper and plastic products o Pest droppings Iodine o Inks Volatiles o Inks Allergens o Incorrect Labels Bisphenol A o Rigid plastics o Metal cans Chemical Hazards o Non-food grade lubricants o Heavy Metals
5 Biological Bird drops Rodent nest Pallets Outside Pests of many kinds can contaminate our plants o o o Leaking roof causing mould Dirty sinks and wash-up areas causing mould or bacteria Pallets kept outside being contaminated by pests
6 Chemical Chemicals can easily contaminate packaging materials if handled carelessly cleaners pesticides and sanitizers
7 Chemical Chemicals may be poisonous Chemicals include: Solvents Lubricants It s important to make sure chemicals do not come into contact with food packaging materials
8 Chemical Inks, dies and coatings Not Food Grade Not used on food contact surface FDA or CFIA compliant For the application Contact or non-contact Must be Food Grade for direct contact
9 Physical Hazards Foreign objects not normally found in food Keep foreign objects out of food and packaging Broken Glass Or wood chips Hair Food or drink
10 Physical False finger nails have become dislodged and have been sent into a food plant with the packaging material False nails can dislodge
11 Physical Snap off blades cause a hazard because the piece of blade that has been removed from the knife can easily get into your finished packaging and then into your customers food plant An uncontrolled blade fragment in a food product is a serious threat to food safety and may cause serious injury to a consumer
12 What is HACCP? Hazard Analysis and Critical Control Point HACCP is a systematic and preventative approach to food safety that addresses biological, chemical and physical hazards through preventative action rather than by finished product inspection. The Food & Agriculture Organization (FAO) and the World Health Organization (WHO) established the Codex Alimentarius Commission. In 1991, Codex developed guidelines for HACCP application. This is getting wide international acceptance.
13 What does HACCP do? HACCP ensures that preventative food safety controls, based on science, will be applied in a systematic and consistent manner
14 Government Sponsored Agriculture and Agri-Food Canada - The Canadian Food Safety and Quality Program (CFSQP) Canadian Food and Inspection Agency Canadian Food Safety Adaptation Program (CFSAP) and Food Safety Enhancement Program (FSEP) Influencing and encouraging our industry partners to develop and implement national systems Supporting an integrated approach for the development and achievement of these systems Effectively branding Canada and US
15 Who Has Been Involved? Food Industry Fillers, Brand Owners, and Retail Organizations They use and specify the materials Packaging Suppliers Converters, Manufacturers, Importers, Brokers, Designers, Machinery Suppliers Raw Material Suppliers Resin, metals, glass, paper, inks Government Stakeholders
16 Prerequisite Program Before HACCP a good Prerequisite Program should address the majority of food safety concerns Premises Security Building exterior Building interior (design, construction, maintenance, lighting, ventilation, waste disposal, employee & sanitation facilities, water, steam, ice Transportation and Storage Carriers quality, temperature controls, storage Equipment Appropriateness of design Sanitation and Pest Control Good housekeeping Personnel Training Hygiene and health requirements Terrorism Recall and Traceability
17 HACCP Standard The following sequence of 12 steps is the recommended approach for the development of a HACCP program: 1. Assemble HACCP team 2. Describe product 3. Identify intended use 4. Construct process Flow Diagram and Plant Schematic 5. Conduct on-site verification of Flow Diagram and Plant Schematic 6. Identify hazards. List preventative measures to control (HACCP principle 1) 7. Determine Critical Control Points - (HACCP principle 2) 8. Establish limits at each Critical Control Point - (principle 3) 9. Establish procedures to monitor Critical Control Points - (principle 4) 10. Establish corrective action to take in case of a deviation - (principle 5) 11. Establish procedures to verify systems are working correctly - (principle 6) 12. Establish effective record keeping - (principle 7)
18 HACCP Plan Program HACCP Plan development involves analysis and filling out of the following set of forms: Form 1: Product Description Form 2: List of Product Ingredients and Incoming Materials Form 3: Process Flow Diagram Form 4: Plant Schematic Form 5: Biological Hazard Identification and Control Form 6: Chemical Hazard Identification and Control Form 7: Physical Hazard Identification and Control Form 8: Critical Control Point Determination Form 9: Hazards Not Controlled by Operator Form 10: HACCP Plan
19 Packaging for Food Safety GFSI Requirements for the Packaging Industry
20 Food Safety Management for Packaging Materials General Requirements A standard requires that the elements of the organisation s Food Safety Management System for packaging materials be documented, implemented, maintained and continually improved. The management system shall: a. identify the processes needed for the effects of packaging of Food Safety Management system b. determine the sequence and interaction of these processes and procedures c. determine criteria and methods required to ensure the effective operation and control of these processes
21 Food Safety Management for Packaging Materials General Requirements d. ensure the availability of information necessary to support the operation and monitoring of these processes e. measure, monitor and analyse these processes and implement actions necessary to achieve planned results and continual improvement f. ensure that packaging used to impart or provide a functional effect on food such as shelf life extension shall be validated for all food types it is to be used on, where known g. validate packaging design and development to ensure food safe and legal manufacture
22 Management Responsibility A standard shall require the supplier to establish a clear organizational structure, which unambiguously defines and documents job functions, responsibilities and reporting relationships of at least those staff, whose activities affect food safety The structure effectiveness shall be periodically reviewed by management
23 Management Commitment A standard shall require that the organization s senior management provide evidence of their commitment to establish, implement, maintain and continually improve the food safety system
24 Specified Requirements A standard shall require that the organization ensures that for all inputs to the process, items and services (including utilities, transport and maintenance) purchased/provided and having an effect on food safety from packaging materials, documented specifications are prepared, effectively controlled, maintained, securely stored and readily accessible when needed A standard shall require that a specification review process is in place A standard shall require that the suitability of all packaging materials shall be supported with evidence of compliance for the intended purpose and have legal compliance for the country of use, where known
25 Internal Audit A standard shall require that the organization has an effective internal audit system in place to ensure compliance to process and operations procedures as well as to cover the scope of the effect of packaging on food safety systems including the Hazard and Risk Management system.
26 Incident Management A standard shall require that the organization establish, implement and maintain an effective incident management procedure for all packaging materials it supplies. This shall cover planning for product withdrawal and product recall which shall be tested on an adequate and specified frequency
27 Product Labeling A standard shall require the organization to ensure that all food packaging materials are suitably labeled/ identified
28 Traceability A standard shall require that the organisation establish, implement and maintain appropriate procedures and systems to ensure: Identification of any out-sourced product, inputs or service related to food safety; Product identification that includes as a minimum a unique product code and manufacturer s identification logo or mark to identify the batch or individual item as required by the customer
29 Traceability Record of purchaser and delivery destination for all products supplied. Identification of recycled materials and any other materials, from whatever source, that may give rise to food safety issues Implementation shall be timely and information produced shall be accurate Traceability shall include the material source (one stage back), throughout all production processes, on to internal and external warehousing and the customer (one stage forward).
30 Thank you
31 THANK YOU
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