FOOD SAFETY MANAGEMENT SYSTEMS FOR FOOD PACKAGING

MANUFACTURINGVive la Différence

Tom DunnFlexpacknology LLC

How do These Relate to Each Other ?

Food Safety Management System

Say what

you do

Do as planned

Record as done

Actual vs.

Expected

Act on varianc

es

Food Packaging Manufacturing

•Bottles•Cans•Bags•Boxes•Trays•Liners

Food safety and packagingChoking hazard: film wrapper

Nauseating odor: box liner

Illegal chemical: brick box

glass shards: metal-capped jar

Carcinogen: film lamination

AgendaPoints to cover

• FSMS for manufacturing food packaging• Good manufacturing practices

• Rules of management systems• Cost of food safety

• Enforcement of management systems

• Expectations of management systems

@ 40,000 feet

Public Health

Supply chain

integrity

Societal Optimu

m

I. FSMS for manufacturing food packaging• Safe Materials

• Compositionally fit for:• Food type• Use Conditions

• Safely made• Good manufacturing

practice (gmp)

• Suitable purity• RM supplier FSMS• Internal

storage/handling

Safe materials (relative to food & use)

Safely made (with a bias toward safety)

•Good manufacturing practice

1. Establishment2. Control of Operations3. Maintenance & cleaning4. Hygiene5. Transportation6. Product Info & awareness7. Training

•GMPs

• All have same basic structure

• Details depend!• What is being manufactured?

• Hazard assessment• Risk analysis• “Prerequisite programs (PRPs)

Good manufacturing practices

• Basic structure: stays the same

• Details: relative to product manufactured

• Compare to ‘speed limit”

Good manufacturing practices

• Basic structure: stays the same

• Details: relative to product• Safety hazards to Product?• Practice(s) mitigate risk?• Reduce frequency of risk

occurring• Reduce severity of actual

event

Manufacturing facility

GMP mitigatio

n

Hazards to

product

Mitigated

product hazards

HACCP•HA

• Hazard Analysis• Biological hazards• Chemical hazards• Physical hazards

• Do GMPs satisfactorily mitigate hazard?

•CCP• Remaining hazard = unacceptable

risk?• Critical Control Point

Control limitsMonitoring procedureCorrective actionVerificationRecordkeeping

Manufacturing facility

GMP mitigatio

n

Hazards to

product

Mitigated

product hazards

Incoming resin hazards SAFETY HAZARD CATEGORYBiological?Chemical?Physical?

GMP INDICATED? Pathogens killed at extrusion temperatures. *Regulatory composition Contaminates filtered out at screen pack* Good hygiene practices still needed post-

extrusion

Suitable purity (supply chain integrity)

Substance

Raw material

Article

FoodSupplyChain

II. Management systems rulesCommand & control model Contract law model

Rules of management systemsCommand & control model Contract law model

Rules of management systemsFirstly, do no harm Comply with all relevant

laws

Command & control vs. Contract models

Global Food Safety Initiative•Reduce food safety risks with equivalence and convergence among effective FMSs.

•Manage global food system cost: eliminate redundancy and improve operational efficiency

•Provide international stakeholder platform for collaboration, knowledge exchange & networking

Hippocratic Oath• Firstly, do no harm• What is the positive this

does? …Avoids food borne illness

and related disease

Global Food Safety Initiative•A program of The Consumer Goods Forum (Paris)

•GOVERNANCE: major global retailers, manufacturers and food service operators

•VISION: “Safe food for consumers everywhere”.•MISSION: to provide continuous improvement in food safety management systems to ensure confidence in the delivery of safe food to consumers worldwide

•METHOD: Technical working groups develop and maintain “Guidelines” in order to determine equivalency between FSMSs (“Benchmarking”

Contract law model for societal optimum

Public health

Supply chain integrity

Econ

omic

System to deliver diverse/low cost goods to public

Envi

ronm

en tal

Material & energy efficient Delivery system

Socia

l

Reliably safe & nutritious food

Sustainable Business Model

Retailers: “biggest skin in the game”

Supplier Processor Retailer Consume

rs

Value Added

Elements of food safety costs • Failure

• Falls short of specification• Internal: before delivery• External: after delivery

• Appraisal• Product testing• Quality control

• Prevention• Compliance capability• Investment

Examples of safety costs

• Failure• Internal

• Down-grade• Re-work• Re-inspect

• External• Handle complaints• Manage recalls• Lose goodwill

• Appraisal • Inspect

• Raw material• Work in process

• Measure• Equipment capital• calibration

• Prevention• Train• Maintain

preventatively • Houseclean• Operate capable

process in control

Packaging: liability multiplier

70 x Value AddedMulti-layer film:$100 k

Filled packages:$4 million

Retail packages:$7 million

III. Management systems enforcement

Securities and Exchange Commission

Certified Public Accountants

Management systems enforcement

Securities and Exchange Commission

Certified Public Accountants

• Roles• protect investors• maintain fair, orderly, & efficient

markets• facilitate capital formation.

• Roles•  accounting• auditing• financial reporting• internal controls • legal compliance.

Safefood

Supply chain

integrity

Public well being ($ , )

Complimentary food safety roles

FDA FSMS Auditor

IV. Management systems expectations1. Scheme owners “benchmark” their system to the GFSI guidelines

1. BRC2. SQF3. IFS4. FSMS 22000

2. “Certifying Bodies” (CB) obtain license to audit to the system1. Auditors have specific training to the scheme and for auditing activities2. Auditors have relevant industry experience and/or training

3. Manufactures hire a CB to audit their system1. “Evidence”: ongoing management of food safety system practices,

elements, commitment2. Much more than housekeeping inspection

Management systems expectations•One world. One standard, One annual audit

•Employee awareness of role in food supply chain•Lower failure and appraisal safety costs•Higher probability of distributing low/no risk product to market

•Fewer market recalls

ConclusionFood packaging can pose risks to foodCommand & control model has limits$takes can be highContract model complements command & control Contract model targets continuous improvement3rd party certification compares to financial auditAlign organization toward food safety

Public Health

Supply chain

integrity

Societal Optimu

m

Thank you!

Questions?