Are Food Producers and Retailers Taking Enough Due Diligence in Auditing Packaging Suppliers?
By Larry Dworkin
While a growing number of food producers and retailers are requiring packaging suppliers to be Hazard Analysis and Critical Control Points (HACCP) compliant, many of these companies may not be taking enough due diligence in auditing their suppliers.
In essence, packaging materials are part of the food processors’ ingredient list, and it is only common sense that they should be treated the same as any substance when it comes to food safety.
Although numerous manufacturing processes are used in packaging, many user companies believe that one general standard fits all when it comes to implementing a food safety standard for packaging materials.
However, each manufacturing process has its own unique issues when it comes to understanding the necessary science in developing an HACCP-based food safety standard to eliminate risks. Therefore, a food safety standard must be based on the packaging science tailored to the individual manufacturing process.
That was the conclusion of a 120-plus-person steering committee in the development of the PAC Packaging Consortium’s initial HACCP-based PACsecure food safety standard for individual materials in 2005. [Note: This standard was the forerunner to the International Featured Standards (IFS) PACsecure food safety standard for individual packaging materials that was recently approved by the Global Food Safety Initiative (GFSI); see “PAC Packaging Consortium”]
The committee consisted of major North American food companies, packaging converters, suppliers of plastic resins, paper, metal and glass, as well as suppliers of inks, dyes and adhesives, and government food agencies.
Most interestingly, many of the food producers on the committee initially tried to adapt a food-based standard to the packaging processes. It didn’t work due to the complexities and science of packaging.
Complexities Not Understood by All Packagers
There are 24 common manufacturing processes used in producing packaging materials. Six are used in the production of flexible plastics, three for rigid plastics, three for paper, 11 for metal containers and one for glass. Composite packages are based on the above processes.
These processes are extremely complex, and as discovered in our steering committee meetings, many individual packaging producers are not aware of all of the complexities related to their specific manufacturing process. Even packaging competitors using the same materials can experience different issues.
If some packagers are not aware of all of the complexities, then how can an auditor from a food company know the right questions to ask unless he or she has a comprehensive understanding of each process? Unfortunately, most do not and depend on the packager for this type of information.
In the production of flexible plastics, for example, one of the six processes involves extrusion. Within this category alone you can be working with polyethylene, polypropylene, polyester, nylon, polyvinyl chloride and so on.
Each of these, in turn, uses a multitude of other ingredients related to antiblock, antifog and antistatic additives, colorants, shelf-life additives, UV inhibitors and antioxidant applications. Add to this processing aids such as extruder purging agents, masking tape, silicone, solvents for cleaning and conditioned air. Then there are the in-plant requirements for cleaning materials, pesticides, water treatment, maintenance materials, testing chemicals and coolants. On top of this are the applications of numerous types of labels and adhesives, inks and dyes—the list goes on, covering hundreds of combinations of the above.
Then there are questions to know about the migration rates of these materials and chemicals and how they interact under different conditions, plus how all of this relates to biological, chemical and physical hazards.
Packaging Science Tailored to Individual Processes
In a departure from packaging standards that were based on the principle that one size fits all, the IFS PACsecure steering committee developed individual workbooks for each of the 24 common manufacturing processes used in the manufacture of paper, flexible plastics, metal, glass and composite packaging materials.
In effect, it takes the standard “down from the 60,000-foot level to the shop floor,” better allowing individual companies to use a science- and risk-based approach in developing their individual HACCP programs.
The workbook is basically an implementation tool outlining the chemical, biological and physical implications and controls of almost every material, chemical and process used in the manufacture of packaging.
It is designed to help control the conditions of the premises (inside and outside a plant), transportation and storage, sanitation and pest control, equipment and personnel—as well as terrorism and security concerns, recall and traceability.
It also provides CCP determination, process flow diagrams and examples of how to fill out all forms. It is designed to help both individual packaging organizations and auditors better identify any issue related to an individual process.
As important as having a good grasp of the science and risk of packaging materials is, the key to success is a company’s prerequisite program or Good Manufacturing Practices (GMPs).
In addition, the committee is working on more GMP tools that will identify acceptable limits, monitoring procedures, deviation procedures, verification procedures and records for all materials, chemicals, processes and allergens.
These tools will further strengthen the knowledge base of the individual company as well as auditors from food processors and retailers and for independent, third-party organizations auditing to GFSI.
Only by working together can the industry ensure that packaging suppliers adhere to HACCP-based food safety standards, which must be grounded on understanding the packaging science, tailored to individual manufacturing processes, which is critical to eliminate risks.
Larry Dworkin is the former director of government relations for The Packaging Consortium (formerly Packaging Association of Canada). In 2001, he headed up a team of more than 120 companies (packaging converters, food companies, retailers and material suppliers) and government to develop an HACCP-based food safety standard that in 2013 became the basis for the GFSI-recognized IFS PACsecure standard for individual packaging materials.