Are you a packaging supplier to the food industry? How confident are you that you fully meet the food safety management system certification requirements? Beyond that, are you compliant with the food fraud prevention requirements? Read this content for clarification and support.
Packaging companies often supply many industries, including the food industry. Those packaging suppliers often do not consider themselves to be in the food industry, so they do not feel they need to comply with food industry requirements. This is an INCORRECT assumption. ANY company that supplies ANY product or service to the food industry IS required to meet food safety management system compliance requirements. This includes the food fraud prevention aspects of that certification.
That said, often, the food safety or food fraud vulnerability is so low that there are few or no controls required. Often, the only requirement is to occasionally conduct a vulnerability assessment and continue to monitor the overall process controls.
Food Safety Laws and Regulations
Broadly, the Food, Drug & Cosmetics Act (FDCA or FD&C Act) requires a hazard analysis:
- ‘“The [food safety] hazard analysis must be written regardless of its outcome” [21CFR507.33 (a)(2)] and “The hazard may be intentionally introduced for purposes of economic gain.” (iii).’
This applies to all food-related products, including packaging. FDA does not provide much more detail as it relates specifically to food packaging for food fraud prevention.
Food Safety Standards and Certifications
The food industry has developed common standards and certifications based on ISO 22000 Food Safety Management and the Global Food Safety Initiative (GFSI) benchmark. These are applied in standards such as SQF, BRC/ BRCGS, FSSC 22000, IFS, and others. The standards, support materials, and guidance for these standards provide more insight for packaging suppliers.
It is clear that packaging and food fraud are a focus:
- Food Packaging Hazard (ISO 22002-4, ISO 24021): biological, chemical, or physical agent in food packaging, or condition of use, with the potential to cause an effect in the food leading to adverse health effects.
- Also, the ISO 22000 section on “4.1 Understanding the organization and its context” states, “The organization shall identify, review, and update information related to these external and internal issues.” This includes a note stating, “Understanding the context can be facilitated by considering external and internal issues including but not limited to… food fraud, food defense and intentional contamination…”
From the GFSI Position Paper on Food Fraud (GFSI, 2014), it is clear that packaging is a concern:
- “Food fraud: including the subcategory of economically motivated adulteration, is of growing concern. It is deception of consumers using food products, ingredients, and packaging for economic gain and includes substitution, unapproved enhancements, misbranding, counterfeiting, stolen goods or others.”
Further, the GSFI guidance document provides more details:
- “GFSI scope of recognition M – Production of Food Packaging includes the following products, services, or methods of production:
- “Production of food and feed packaging,
- “Packaging materials,
- “Packaging components in the form of raw materials, part processed, semi-converted, converted or fully finished packaging materials and products for use in the supply chain.”
For those items, there is a requirement for the package and packaging to be effective as intended:
- “FSM M 1.2 – Food Safety Management – for Packaging Materials General Requirements – The management system shall ensure that packaging used to impart or provide a functional effect on food such as shelf-life extension shall, where known, be effective within its own specified criteria.”
There are also specific requirements for food companies who purchase packages or packaging:
- FSM M 15.1 Purchasing – The standard shall require that the organization controls the supply management processes to ensure that all externally sourced materials and services which have an effect on food safe packaging materials conform to specifier and regulatory requirements including food fraud mitigation plan requirements.
- FSM M 15.4 Purchasing (non-approved supplier) – Use of non-approved suppliers shall be acceptable in an emergency situation provided the facility has been assessed and the product meets the specification.
The package and packaging supplier must meet the exact compliance requirements as the rest of the food industry: conduct a food fraud vulnerability assessment, create a food fraud prevention strategy to manage the process, and coordinate these activities with the overall food safety management system. Together, this is the Vulnerability Analysis and Critical Control Point plan (VACCP):
Table 1: The GFSI Food Safety Management System Requirements
for Addressing Food Fraud Prevention
|FSM M 21||Food fraud vulnerability assessment||The standard shall require that the organization has a documented fraud vulnerability assessment procedure in place to identify potential vulnerability and prioritize fraud mitigation measures.|
|FSM M 22.1||Food fraud mitigation plan||The standard shall require that the organisation has a documented plan in place that specifies the measures the organisation has implemented to mitigate the public health risks from the identified fraud vulnerabilities.|
|FSM M 22.2||Food fraud mitigation plan||The standard shall require that the organization’s fraud mitigation plan and shall be supported by the organisation’s Food Safety Management System.|
Adapting Procedures to the Packaging Industry
While the food fraud vulnerability assessment and prevention strategies can be quite complex and time-consuming, the activity is much simpler for some products. Due to the nature of the packaging raw materials, manufacturing process, and supply chain, the packaging-related food fraud vulnerability assessment is often “low” or “very low.” Thus, based on these findings, the food fraud prevention strategy activities are often very simple or may only include some level of ‘ongoing monitoring.’
A professional education program has been developed to support the packaging industry and other suppliers to the food industry such as storage and transportation, pest control, cleaning services/ laundry, and related processing aids. Our live, in-person seminar covers the food fraud compliance requirements that apply to the packaging and related industries. The course includes adapted packaging specific procedures for gathering information, conducting a vulnerability assessment, implementing a prevention strategy, and then the ongoing review (together, this is VACCP or a vulnerability assessment and critical control point plan).
Food Industry Suppliers Seminar – Including Packaging
For more information, here is a link to the seminar:
- Food Fraud Compliance for Food Industry Suppliers Seminar (October 24-25, 2023): https://foodfraudpreventionthinktank.com/course-product/suppliers-october-24-2023/
- There is often an INCORRECT assumption that a packaging supplier may not need to have a food safety management system certification (e.g., the GFSI/ ISO 22000 benchmark in standards from SQF, BRC/ BRCGS, FSSC 22000, IFS, and others).
- Further, there is also often an INCORRECT assumption that the food fraud-related concerns from packaging are so low that they do not need to be assessed or managed.
- To support your compliance activities, consider the Food Fraud Compliance for Food Industry Suppliers Seminar (October 24-25, 2023): https://foodfraudpreventionthinktank.com/course-product/suppliers-october-24-2023/
- Food Fraud Overview and Compliance Requirements for Packaging, PJR Webinar, Guest Webinar, March 15, 2018, URL: https://www.youtube.com/watch?v=6XK0UI2PQjU