Reducing Food Safety Risks through Recognized Systems · Reducing Food Safety Risks through...
Transcript of Reducing Food Safety Risks through Recognized Systems · Reducing Food Safety Risks through...
Reducing Food Safety Risks through
Recognized Systems Thomas Bouraoui -- Exopack Corporate Director of Quality & CI
2/26/2013 2
Agenda
CPG Expectations
FSMA overview
GFSI overview
The “Big 4” GFSI Standards
Summary
CPG Expectations
Necessary mindset
If your product touches food at some point in the downstream supply chain, you are a part of the Food Industry.
Adapted from: Food Safety Alliance for Packaging
Treat Food Packaging (Human and Pet) with the same food safety rigor as food – look at potential risks from design to consumption
Typical Expectations for Packaging Supplier Approval
Supplier survey / risk assessment
Site Audit:
3rd 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
Food Safety is Still Big News
Adapted from: Food Safety Alliance for Packaging
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
U.S. and Canadian Food Recalls - 2011
Source: Food Industry Report Vol. 24 No. 4 April 2012
0
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E. coli Listeria Salmonella ForeignMaterial
UndeclaredIngred/
ALLERGENS
U.S. 2011
Canada 2011
Pro-active packaging suppliers prevent mixed labeling
A priority concern:
“misbranding” issue
if allergens = safety issue
A pro-active approach:
assess risks
human and electronic controls
VERIFY
1.3 verify Roll History ticket info against……_____
1.4 load jumbo onto unwind1.5 check off jumbo roll # on p revious op ertn_____
Begin production of new WO
6.2 start mach ine and begin p roduction
2.5 confirm p ap erwork (FG slit roll tally sh eet,
Step # 6
6.1 conduct required quality checks and p ap erwork
Step # 5
5.1 sign off on checklist
Sign off Line Clearance
Remove splice and wind onto
new cores 4.2 jog web until sp lice p asses core4.3 cut off tail w ith sp lice and disp ose of it
4.4 attach new WO to core p er w ind instructions
roll doc area3.5 do not m ix rolls on p allets
Step # 4
4.1 p lace new cores onto rew ind arm s or sh afts
Step # 3
3.1 comp lete all docs in job jacket + p lace on p allet
Remove all of previous WO
from machine area
3.2 current job jacket on roll doc p allet if ap p lic.
3.3 move all current FG material to p allet wrap p ing
3.4 wrap p allet of roll doc material before moving to
Advance new WO thru
machine2.2 remove current slit rolls; sp lice stays on m 'ce
2.3 p lace core tags onto all rolls (roll doc & finish ed)
2.4 bag rolls (if required) roll doc rolls w sticker exp laining defect & WO)
Splice different WO's at
unwind1.2 signoff on Startup Checklist (cop y verified)
Step # 2
2.1 jog and stop sp lice just before rew ind nip
1.6 sp lice current WO & new WO w 2" brown tap e
Step # 1
1.1 verify new WO jacket samp le to new WO jumbo
MAJOR STEPS
KEY POINTS
Finishing Line Clearance
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
The Food Safety Modernization Act
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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
FSMA signed into U.S. law Jan. 4, 2011
Everyone in the chain
must do their part.
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New rules may take several years to go into effect
Trend: though FDA does NOT require HACCP for packaging suppliers; customers increasingly require it!
Where FSMA is headed…. and what does it mean to packaging suppliers?
Preventive focus Proactive bias
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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!
Proactively prepare until rules finalize
FSMA is predominantly HACCP related …
2/26/2013 Source: Diagram adapted from Certified HACCP Auditor Handbook 15
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
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 5
Pre
lim
inar
y Ta
sks
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
7 H
AC
CP
Pri
nci
ple
s
GMPs / PRPs
CCPs
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.
Don’t overlook keys to success
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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)
Global Food Safety Initiative (GFSI)
Global Food Safety Initiative
2/26/2013 Source: adapted from GFSI website 20
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
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”
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):
The Big 4 GFSI Schemes
The “Big 4” GFSI recognized Standards
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IFS – PACsecure
(http://www.ifs-certification.com)
FSSC 22000
(http://www.fssc22000.com/en/)
BRC – Food
(http://www.brcglobalstandards.com)
SQF
(http://www.sqfi.com/)
North American Packaging Supplier perspective
Currently seeking recognition
BRC – British Retail Consortium
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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)
FSSC 22000
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Food Safety Systems Certification
Defined in the two standards:
ISO 22000 – 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.
SQF -- Safe Quality Foods
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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)
Typical Audit Problems (example: SQF)
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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
IFS PACsecure
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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.
Summary
HACCP is core - - regardless of scheme
Hazard Types
Chemical Physical Biological
Materials and Processes
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
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
Helpful Resources
Food Safety Alliance for Packaging www.iopp.org/fsap
HACCP Models
List of Service Providers -- training and other resources available (e.g., IFS PACsecure, GFSI Certification)
Adapted from: Food Safety Alliance for Packaging
2/26/2013 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: