Challenge Question 2.1: Does the package meet safety, quality and food contact compliance standards?

Answers:

Summary: Why is food safety, quality and compliance important? According to the Canadian Food Inspection Agency (1) “food businesses are responsible for ensuring that the construction materials, packaging materials and non-food chemicals used in their facilities are safe and suitable for their intended use. This is an essential part of good manufacturing practices to prevent the contamination or adulteration of food products from these materials. Food businesses are also required to meet all applicable regulatory requirements of the Food and Drugs Act, the Food and Drug Regulations and the Safe food for Canadians Act and Regulations.”

For the food and food packaging industry safety, quality and compliance is crucial to avoid product recalls and complaints due to packaging, and to ensure use of safe, legal materials and ultimately the health and well-being of customers and communities. Packaging material suppliers must be able to prove compliance and customers must require this. This brings additional benefits such as packaging and material performance, conformance to customer expectations and requirements, meeting regulatory requirements (labeling, claims, etc.)

How do I get my food and food packaging operations certified to the required food safety and quality standards? The approach to achieve safety and quality compliance for companies (food and food packaging operations) is a 6 step process:

  1. Company selects a food safety standard e.g. BRC, SQF, FSSC 22000, IFSPacsecure (table below)
  2. The standard owner provides training for the product safety or quality or production manager (or all aforementioned).
  3. Company conducts a self-assessment audit and gap analysis At a minimum any company should expect to be applying Good Manufacturing Practices (GMP’s), with documentation for validation and applying product and process safety hazard and risk analysis.
  4. Company chooses a certification body that has been approved by the standard owner to carry out an external audit e.g if IFSPACsecure was the chosen standard then the company will chose a certification body approved by IFS who will then send an auditor to assess versus the standard requirements.
  5. The certification body issues a certificate after a satisfactory audit and registers the company with the standard owner as certified to the specific standard. 
  6. Companies are required to renew their certification annually and must perform an annual internal audit.
Food safety standard providerStandard overview
BRCGS Food Safety https://www.brcgs.com/our-standards/food-safety/  Developed with input from industry, it provides a framework to manage product safety, integrity, legality and quality, and the operational controls for these criteria in the food and food ingredient manufacturing, processing and packing industry. GFSI recognized (2).
Safe Quality Food Program (SQFI) https://www.sqfi.com/what-is-the-sqf-program/  The program is a rigorous and credible food safety and quality program that is recognized by retailers, brand owners, and food service providers world-wide. Recognized by GFSI, the SQF family of food safety and quality codes are designed to meet industry, customer, and regulatory requirements for all sectors of the food supply chain – from the farm all the way to the retail stores.
FSSC22000 https://www.fssc.com/schemes/fssc-22000/#what-is-22000  The scheme provides a certification model that can be used in the whole food supply chain to ensure food safety standards and processes. FSSC 22000 is GFSI recognized and follows the food chain category description as defined in ISO/TS 22003.
IFS PACsecure https://ifs-packaging.com  IFS Certified companies ensure their services, materials, and products meet customer and legal requirements. The IFS PACsecure Standard is applicable for the production, processing, or conversion of components and materials intended for use as primary or secondary packaging in food, cosmetics, class 1 medical devices, OTC drugs pharmaceutical products, household, and personal care products. They support businesses in meeting the growing transparency and traceability demands in the market.(3)

What do I need to know about the use of recycled plastics for food packaging?

The use of recycled materials has become a government of Canada priority, as part of Canada’s goal of zero plastic waste by 2030. Moreover, as public demand grows, manufacturers of food packaging will likely increase their use of recycled materials. Therefore, to support this plastic waste reduction policy and to promote the safe use of these materials, BCS  has updated its previous guidelines to assist recyclers, manufacturers and sellers of plastic materials in determining the safety and acceptability of post-consumer recycled (PCR) plastics for this purpose (4).

What do I need to know about clean packaging and chemicals of concern?

Canada is catching up on regulation of PFA’s and other chemicals of concern(5). This is typically addressed through CEPA Canadian Environmental Protection Act (6).  

Supporting Reference articles and reports

  1. Canadian Food Inspection Agency https://inspection.canada.ca/food-safety-for-industry/eng/1299092387033/1299093490225
  2. Global Food Safety Initiative (GFSI) https://mygfsi.com
  3. IFS is about to release product / packaging guidelines on what food companies should be looking for re safety, quality, compliance – should be available April 2023.
  4. Health Canada guidelines for using recycled plastics in packaging https://www.canada.ca/en/health-canada/services/food-nutrition/legislation-guidelines/guidance-documents/guidelines-determining-acceptability-use-recycled-plastics-food-packaging-applications.html
  5. Clean packaging and chemicals of concern https://www.food-safety.com/articles/8204-in-pursuit-of-clean-packaging-with-no-chemicals-of-concern

Canadian Environmental Protection Act https://www.canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/related-documents.html