Welcome to the second edition of the Food Packaging Safety Forum. Last month, we set the stage for discussing the realities of food safety in this day and age. Now more than ever, members within the food supply chain are commanded to apply industry best practices, which are in a state of evolution as precipitated by the Food Safety Modernization Act (FSMA), Global Food Safety Initiative (GFSI), and other industry best practice-based guidance and processes. Regardless of the medium, these programs and schemes have the obvious objective of ensuring that participants of the food processing and handling supply chain reduce or control risk, thereby minimizing “incidents” at every level of the chain.
Whether through legislation (FSMA) or industry best practice-based guidance and process (GFSI), the general objective is to put growers, providers, processors, vendors, manufacturers converts, their supporting partners, lawmakers and the public on notice that a major irreversible change has taken/is taking place in regard to the global food supply chain entering and within the United States and other developed nations. This is important to note in relation to peripheral supply chain partners (i.e., supplier or vendor of goods or services to the process), because many food safety programs, schemes and related organizations are not US-based, but are US-embraced as representing best practices. Naturally, the public and legislators in other parts of the world are as anxious as we are to control risks and apply best practices for the handing and manufacture of edibles. These programs (FSSC22000 and BRC, as examples) are developed and written to include every aspect of process and performance, which, of course, includes packaging, warehousing, transportation and other peripheral aspects of the food supply chain that are not directly edible, but affect that which is.
While concerns may abound, one should expect that as a standard action, quality function managers of most food manufacturers and retailers, even peripheral partners, have been fully trained in the most visible and broadly embraced global food and packaging-related safety programs. These global programs preach a similar mantra:
- Knowledge – of the objectives and general process
- Awareness – of risks, both general and specific to each industry and situation
- Analysis – of risks, severity and need for action
- Action – to find, control and capture risks before they get into the public domain
- Training – of all employees at every level with appropriate internal, rules, policies and best practices
- Inspection – First and second level internal and 3rd party external to constantly monitor and validate
- Responsibility – a precept that makes it clear that everyone in the chain is responsible on some level for the efficacy and safety of the product or process and that finger pointing or ignorance is no longer a valid defense or substitute for best practices.
Your partners in the food supply chain, as well as regulators and customers, expect you to be fully accepting of and in compliance with these principles. One break in the supply chain can compromise the entire process and no one who has spent the time, money, and resources to become compliant has any tolerance for a primary or peripheral partner negatively affecting the process.
A threatening reality looms, however: what is a supply chain participant to do in the event that they or one of their critical supply partners cannot fully meet all of the requirements within even the most liberal food safety program? Just as troubling, what strategy does one employ when confronted with a critical partner (raw material supplier, for example) who makes it clear that if full compliance is mandatory, they will, with regret, be forced to discontinue supplying goods to the customer?
These are real situations and circumstances, which confront vendors today. I will begin to address these conundrums in future installments of the Forum, along with other relevant food and packaging safety challenges. Join me as we continue to explore details, considerations and best practices relating to the subject of packaging safety and suitability. Naturally, we welcome your comments, observations and real-life situations.
About the author: Gary Kestenbaum is the Sr. Food Packaging Safety Consultant at EHA Consulting Group, Inc. (ehagroup.com). Kestenbaum has 40 years of experience in the food industry including functional assignments as a food ingredient supplier with National Starch, a product developer with General/Kraft Foods and a packaging developer and packaging engineer with Kraft Foods.