Date post: | 16-Jul-2015 |
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Today’s Presenters
Debra Krug-Reyes• Principal in the Food Safety and
Quality Auditing GroupConAgra Foods
George Gansner• Director, Global Marketing and
Business Development; Manager -Americas
International Featured Standards (IFS)
Food Safety and Packaging:
What do CPGs Expect of Suppliers?
Debra Krug-ReyesFood Safety and Quality Auditing
ConAgra Foods, Inc.
August 14, 2014
Agenda
Current Status
Typical Expectations from CPG/Food Companies
Product Recalls
Risk-Based Preventive Programs
6
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
The Federal Food, Drug and Cosmetic Act
The FDA regulates Food Contact Materials based on the premise that they
are potential Food Additives
Section 210(s) of the Act:
A Food Additive: “Any substance the intended use of which results in or may be reasonably expected to result … in its becoming a component of food”
Any substances which then become part of a food by being transferred from the packaging are considered “Indirect Food Additives”
Conclusion: Packaging Materials are potential Food Additives
8
Typical Expectations for Packaging Supplier Approval
Supplier survey / risk assessment
Site Audit:
3rd party; GFSI or other Food Safety certification;
CPG internally developed audit
Typical assessments:
GMPs, Employee Practices, Training
HACCP/Food Safety Risk/Hazard Assessment Controls in place to eliminate identified risks– CCPs or prerequisites
Supply chain management/approval process
Raw material regulatory approvals
Chemical migration testing
9
0
100
200
300
400
500
600
700
800
900
1000
E. coli Listeria Salmonella ForeignMaterial
Packaging-Not Labeling
UndeclaredIngred/
ALLERGENS
U.S. 2011
U.S. 2012
U.S. 2013
U.S. Food Recalls – 2011-2013
11Source: Food Industry Report , Vol. 24, 25, 26 No. 4 April 2012, April 2013, April 2014
Canada Food Recalls 2011-2012
Source: Food Industry Report, Vol. 24 and 25, No. 4, April 2012 and April 2013
0
50
100
150
200
250
300
E. coli Listeria Salmonella ForeignMaterial
Packaging- NotLabeling
UndeclaredIngred/
ALLERGENS
Canada 2011
Canada 2012
12
Impact of Recall Indirect Costs
Product Reputation
LOSS OF CONSUMER CONFIDENCE in the brand, the product category, the company, the food industry
Other brands and other companies are affected
Product Recovery
Disposal Costs
Analytical Costs
Shelf-space
13
Top Food Safety Related Issues Associated with Packaging
Undeclared/Unlabeled Allergens /Misbranding Wrong food or wrong package
Mixed labeled packaging materials– Packaging Supplier or Food Plant errors(e.g., labels, cartons, film, lids, cups,…)
Human errors– multiple potential sources– Murphy’ Law
Incorrect Label Printing Copy review errors
Prior print versions re-appear
Printing changed or lost
Chemical Migration Migration into product (e.g., film, pallets, ink…)
May be “Perceived” food safety issues– odors, taste Social Media Communication (e.g., BPA)
14
16
Reaction to MILK Reaction to PEANUTSNormal
Food Allergies can lead to serious reactions– potentially fatal
Hostess Recalls Chocolate Mini Muffins–
Mislabeled/Unlabeled Allergen
Banana Nut muffins packaged in the wrong bag-- bag was labeled as “Chocolate Chip”, walnutspresent in the muffins not listed on the label–
Unlabeled Allergen and Misbranded Product
October 1, 2010 – Consumer Reports Food Safety Alert
17
OM Wieners with Cheese in
Classic Wieners Package–
Not labeled as containing cheeseUNLABELED MILK
ALLERGEN
Fox News April 20, 2014
18
Pro-active packaging suppliers preventmixed labeling
Controls to prevent mislabeling:
Implement strict controls at points where human error could occur
Changeover/Line Clearance checklists
Print copy reviews
Electronic Vision Systems
Rework controls
Employee training and reinforcement
Joint Responsibility:
Controls at both the packaging supplier AND the food plant
22
Chemical Migration
Migration into product
Sources– film, ink, pallets, …..
Perceived or real risk?
Social Media (e.g., BPA)
News reports
24
Kellogg’s Recall 28MM Boxes of Cereal–
Cereal box liners imparted bad taste and odor to the food
Associated with nausea and vomiting in some consumers. The source was identified
as higher than normal levels of a chemical (2-Methyl Naphthalene) in the liners
June 2010 25
Johnson & Johnson Recalls Over 60MM Bottles of
Pain Relievers Due to Musty Odor (3 Recalls)
The odor was caused by trace amounts of a chemical (tribromoanisole(TBA)) formed as a by-product of mold growth on high-moisture
wooden pallets
In addition to causing an unpleasant odor, TBA has been associated with temporary and non-
serious gastrointestinal symptoms.
Jan - Oct 2010
26
Supplier approval programs (resin and other materials)
Letters of Guarantee/Certificate of Conformance
Chemical Migration testing
Audits of incoming materials
Consider end use of packages (e.g., direct product contact, microwave, hot fill, pH of the food,…)
Packaging supplier and customer must work closely to understand the interaction of the package with the food– consider foreseeable use
Pro-active programs prevent potential chemical migration
27
Other Considerations
CONSUMER PERCEIVEDfood safety/consumer hazards
FORESEEABLE USE of the material
28
Who’s Responsible for Safety
of Packaging Materials?
Joint Responsibility
Packaging Supplier and CPG Manufacturer
31
Joint Responsibilities
Sound Quality Management Systems
Risk Analysis– what “could” happen if….
Controls to prevent incidents
Secondary checks/controls
Prevent potential for human error
Use of technology (e.g., vision systems)
Learn from prior mistakes– yours and others
Remember Murphy’s Law
32
Pro-active food safety programs at packaging
suppliers and food manufacturers can prevent
potential issues
33
Prerequisites & Basics for
HACCP/Food Safety Programs
34
HACCP/ Food Safety
GMPSanitation,
Sanitary Design, Maintenance
Process Control
Microbiological Chemical &
Physical ControlSpecifications
TrainingEnvironmental
MonitoringSupplier Control
Product Traceability &
Recall
Food Safety Across the Supply Chain
HACCP/Food Safety Programs identify
potential hazards/risks and controls that can be implemented to prevent potential hazards
The HACCP approach is a proven food safety
program accepted worldwide– the ultimate goals:
Protect consumers
Prevent / Eliminate Recalls
35
GFSI– Global Food Safety Initiative
Vision: Safe Food for Consumers Everywhere
Mission: Driving continuous improvement in food safety to strengthen consumer confidence worldwide
A strong HACCP/Food Safety program including strong prerequisite programs are essential components of the Global Food Safety Initiative
36
39
Blank area for graphicsThanks to sister CPG companies and the Food Safety Alliance for
Packaging (Technical Committee of IoPP) that contributed content to portions of this presentation.
| 41 | www.ifs-certification.com
Introduction
The IFS PACsecure Standard - in a nutshell
For manufacturers and converters of
packaging materials
To ensure quality and safety of
packaging materials
Food and non-food materials
Meets GFSI requirements
Roll out in North America and Europe
| 42 | www.ifs-certification.com
Introduction
Origin of the Standard
Safety standards for manufacturers of
packaging material
(Packaging Association of Canada - PAC)
Prerequisite ProgramHACCP-plans and
workbooks for hazard identification
| 43 | www.ifs-certification.com
Introduction
Origin of the Standard
PACsecure: development by working group of North America’s largest packaging and food manufacturers
IFS PACsecure is GFSI Benchmarked
IFS PACsecure: Cooperation of IFS and PAC to develop the Standard andmeet GFSI requirements
| 44 | www.ifs-certification.com
Introduction
Structured as IFS Food
Part 1
(Audit protocol)
Part 2
(Requirements)
Part 3
(AB, CB & Auditors)
Part 4
(Report)
• Annex 1 – different IFS Standards
• Annex 2 – Certification process
• Annex 3 – Product scopes
• Annex 1 - Glossary
• Annex 1 – Product scopes
• Annex 1 - Report cover page
• Annex 2 - Audit report
• Annex 3 - Action plan
• Annex 4 - Certificate
| 45 | www.ifs-certification.com
Part 1: Audit protocol
The Standard applies to manufacturers of different packaging materials
Without food contact
With food contacte.g. PE foil for vegetables, tin plate cans for beverages, paper packaging for flour…
e.g. technical products
>> Scope of the audit
>> Product scopesFlex pack.
Rigid
plasticPaper Metal Glass
Other natural
mat.
>> Processing lines shall be operating during the audit
| 46 | www.ifs-certification.com
Part 1: Audit protocol
>> Scope of the audit
IFS PACsecure product scopes Examples
1. Flexible packagingBlown film extrusion of PE films for cheese
wrapping
2. Rigid plastic thermoforming of PP trays for ready meals
3. PaperPapermaking, manufacturing of corrugated
cardboard
4. Metal Drawing of two-piece alu cans for soft drinks
5. Glass Blow-blowing of glass containers
6. Other natural materialsMaterials to be considered as “other natural
materials” are, e.g. wood, clay, cork, jute, textiles,
banana leaves
Multi-componentThe main component of multi component packaging materials (e.g.
drink cartons) has to be mentioned in the scope of the audit on the
report.
| 47 | www.ifs-certification.com
Part 1: Audit protocol
>> Types of audits
Initial audit Follow up audit Renewal audit
• First audit for the
company against the
IFS PACsecure
• All requirements
shall be audited
(complete company
audit)
• Required when
Major and final
score ≥75%
• Auditor focuses on
implementation of
corrective action
related to Major
• Performed on-site,
by the same auditor
• If failure, a
complete new audit
necessary
• Any full audit after
the initial audit
• All requirements to
be audited
• Check corrective
action plan from
previous audit
• Companies are
responsible for
maintaining their
certification
| 48 | www.ifs-certification.com
Part 1: Audit protocol
>> Types of audits
Extension audit
• Between two audits, in case
of new products or processes
• CB shall decide risk based if
audit is necessary, which
requirements are applicable
• In general, extension audit
necessary when risk
assessment or product
scopes or technologies are
different
| 49 | www.ifs-certification.com
Part 1: Audit protocol
Influencing factors
Size of the site
Scope of the audit
>> Minimum audit duration: 2 days (exceptions possible)
Type of production
Number of production lines
Number of personnel
Number of non-conformities ofprevious audit
• all members shall be approved IFS PACsecure auditors
• lead auditor and co-auditor(s) shall be identified
• auditor’s profile shall comply with the activities of the audited factory
• 2 hours of the audit duration are not shareable (for common tasks, e.g.
opening and closing meeting, discussion about audit findings)
• audit time schedule shall indicate which auditor did which part of the audit
| 50 | www.ifs-certification.com
Part 1: Audit protocol
>> Audit team
| 51 | www.ifs-certification.com
Part 1: Audit protocol
>> Scoring system - deviations
Result Explanation Points
A Full compliance 20
B Almost full compliance 15
CSmall part of the requirement
has been met5
D Requirement has not been implemented - 20
| 52 | www.ifs-certification.com
Part 1: Audit protocol
>> Scoring system - Major
• May be given to any requirement (except KO)
• Meaning: substantial failure to meet the requirement (including product
safety/legal issues or if it might lead to a serious health hazard)
• Substracts 15 % of score
>> Scoring system - KO
• KO-requirements may be scored with A (20pts), B (15pts) or D (-50 %)
• “D” leads to non-certification or suspension of certificate
Part 1: Audit protocol
>> Conditions for awarding the certificate
Non conformity Status Action of the auditee Certificate
At least 1 KO scored
with DNot approved
send completed action plan
scheduling of a new initial audit, not
earlier than 6 weeks after
NO
> 1 Major
and/or
total score < 75%
Not approved
send completed action plan
scheduling of a new initial audit, not
earlier than 6 weeks after
NO
Max 1 Major and total
score is
≥ 75%
Not approved
unless further
actions taken
and validated
after follow up
send action plan within 2 weeks after
receiving preliminary report
Follow-up audit max 6 months after the
audit date
Foundation
level
(if Major NC
solved)
Total score ≥ 75% and
< 95%
Approved for
IFS PACsecure
foundation
send action plan within 2 weeks after
receiving preliminary report
Foundation
level
Total score ≥ 95%
Approved for
IFS PAC secure
higher level
send action plan within 2 weeks after
receiving preliminary report Higher level
| 54 | www.ifs-certification.com
Part 2: List of audit requirements
1 checklist
9 KO requirements
>> Key facts
References to the original PACsecure standard in the checklist
Example questions of auditors in the checklist
Examples for KO and Major in checklist
Additional HACCP plans and workbooks available by PAC
| 55 | www.ifs-certification.com
Part 2: List of audit requirements
>> Structure of the checklist, example: trainings
No Requirement PAC
secure-
rqmnt
PAC
secure
- No
What to check?
What should be
asked?
Example for
KO/Major
3.3.4 The contents of training
and/or instruction shall be
reviewed and updated
regularly and take into
account company‘s specific
issues, packaging material
safety, packaging material
related legal requirements
and product/process
modifications.
D 1.2.1–4 4, 5 – How are training contents
reviewed?
<review test>
– When are training
contents reviewed?
– When was the latest
training content update
done?
– What was the content of
the latest update?
<audit results>
– specific issues: non-
conformities, failures
During the on-site
audit evidence was
given that
employees did not
act according to
knowledge trans-
mitted in the training
sessions and this
lead to a product
safety risk.
| 56 | www.ifs-certification.com
Part 2: List of audit requirements
>> Content
• Corporate structure, Management review…
1. Senior Management Responsibility
• Documentation, Record keeping, Risk assessment…
2. Quality and Packaging MaterialSafety Management System
• Personnel hygiene, Training, Staff facilities, Working conditions…
3. Resource Management
| 57 | www.ifs-certification.com
Part 2: List of audit requirements
>> Content
•Legally required documentation, Specifications, Formula/ Configurations, Purchasing, Production and storage areas, Cleaning, Waste, Foreign material, Pests, Maintenance, Traceability…
4. Planning and Production Process
•Internal audits, Calibration, Product analysis, Complaints, Corrective actions…
5. Measurements, Analysis, Improvements
•Site security, Personell and visitors…
6. Packaging Material Defense/Food Defense and External Inspections
| 58 | www.ifs-certification.com
Part 2: List of audit requirements
>> 9 KO requirements – 4 of them in chapter 4 (production process)
Senior Management responsibility (1.2.4)
Personnel hygiene (3.2.1.2)
Specifcations for raw materials (4.2.1.2)
Compilance with customer agreements (4.2.2.1)
Procedures to avoid foreign material (4.12.1)
Traceability system (4.18.1)
Internal audits (5.1.1)
Procedure for withdrawal/recall (5.9.2)
Corrective actions (5.11.2)
| 59 | www.ifs-certification.com
Part 2: List of audit requirements
>> Supporting documents by PAC >> example: CP determination
| 60 | www.ifs-certification.com
Part 2: List of audit requirements
>> Supporting documents by PAC >> example: CP determination
| 61 | www.ifs-certification.com
Part 3: Requirements for CBs and auditors
>> Auditor requirements
IFS PACsecure
IFS Food IFS HPC scope 3
PACsecure
otherpack-stds.
poduct/process
-audit training
poduct/process
-audit training
otherpack-stds.
Key question: is the audited company capable
of supplying safe products that comply with the
agreed specifications?
| 62 | www.ifs-certification.com
Part 3: Requirements for CBs and auditors
>> Audit objectives and principles
• An audit should check the capability of a company
to use its systems and processes to realize a safe,
legal and conform product
• During the audit, the auditor uses objective
evidence on site to check whether safe, legal and
conformant products are actually produced and
delivered
• The aim is, in a given audit situation, to reach
equivalent results regardless of who the auditor is
| 63 | www.ifs-certification.com
Part 4: Reporting and IFS Audit Portal
>> Audit portal and database – where the audits are stored
• Upload
reports
• Manage
companies
• Compare
reports
• …
CBs
• Access to
own audit
data
• Unlock
retailers
• Create sub
accounts
• …
Suppliers
• Search for
suppliers
• E-mail notif.
in case of
certificate
suspension
• …
Retailers
User g roups
| 64 | www.ifs-certification.com
Update
Audit status
>> 23 sites certified, some already twice
Austria and Germany, e.g.:
Canada and USA, e.g.:
| 65 | www.ifs-certification.com
Status
News
• GFSI-recognized since December 2013
GFSI benchmark
• Working group creates training materials
• McDonald‘s Europe accepts IFS PACsecure
Rollout in Europe
• English, German, Italian and Spanish alreadyavailable
• French and Portuguese are worked on
Translation of the Standard
| 66 | www.ifs-certification.com
Conclusion
Review
• Standard for packaging material manufacturersWhat?
• Flexible & rigid plastics, paper, metal glass, othernatural materialsScope?
•Safety & quality for manufacturers
•Reduction of faults and costs
•Meet GFSI requirementsObjectives?
• Independent assessment
• Risk based
• Flexibility of implementationBenefits?
| 67 | www.ifs-certification.com
Conclusion
Benefits
• IFS PACsecure offers up to 1 year to closedeviations
• More flexible requirements
• Truly risk-based requirements
• Guideline included in the checklist
compared to
BRC IoP
• Check of compliance with customer requirements
• IFS PACsecure displays the degree of fulfillment(scoring system with percentage)
• Comparable regardless of language
• Harmonized audit report, comparable to the other IFS Standards
compared to
ISO 22000 + PAS223
IFS PACsecure, Version 1 | Neckarsulm | 11.06.2013| 68 | www.ifs-certification.com
IFS PACsecure, Version 1
Benefits
• IFS PACsecure-Anforderungen prüfen Sicherheit und Qualität von Herstellern und berücksichtigen Kundenanforderungen. So können z.B. Lieferantenaudits reduziert werden
Hohes IFS-Anforderungsniveau
• Der IFS PACsecure-Standard wird durch die GFSI geprüft – dabei werden Qualität und Belastbarkeit der Anforderungen untersucht.
GFSI-Benchmark
• Trotz vieler Gemeinsamkeiten unterscheidet sich IFS PACsecure vom BRC-IoP-Standard. IFS PACsecure fragt z.B. nach:
• Überprüfung der Mitarbeiterverantwortlichkeiten
• Hygieneregeln auch für Besucher und Dienstleiter
• Ständige Verfügbarkeit von Spezifikationen und gesetzl. geforderter Dokumente
• Erfüllung von Kundenanforderungen
• …
Unterschiede zu BRC-IoP
Thank youfor your attention
George Gansner
IFS Management
314-686-4610
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Q&A
Rajan Gupta
George Gansner
Debra Krug-Reyes