1. FOOD SAFETY MANAGEMENT SYSTEMS FOR
FOOD PACKAGING MANUFACTURING
Vive la Différence
Tom Dunn
Flexpacknology LLC

2. How doThese Relate to Each Other ?
Food Safety Management System Food Packaging Manufacturing
• Bottles
• Cans
• Bags
• Boxes
• Trays
• Liners

3. Food safety and packaging
Choking hazard: film wrapper
Nauseating odor: box liner
Illegal chemical: brick box
glass shards: metal-capped jar
Carcinogen: film lamination

4. Agenda
Points 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
Optimum

5. 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

6. Safe materials (relative to food & use)

7. Safely made (with a bias toward safety)
• Good manufacturing practice
1. Establishment
2. Control of Operations
3. Maintenance & cleaning
4. Hygiene
5. Transportation
6. Product Info & awareness
7. Training
• GMPs
• All have same basic structure
• Details depend!
• What is being manufactured?
• Hazard assessment
• Risk analysis
• “Prerequisite programs (PRPs)

8. Good
manufacturing
practices
• Basic structure: stays the same
• Details: relative to product
manufactured
• Compare to ‘speed limit”

9. 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
mitigation
Hazards to
product
Mitigated
product
hazards

10. HACCP
• HA
• Hazard Analysis
• Biological hazards
• Chemical hazards
• Physical hazards
• Do GMPs satisfactorily mitigate hazard?
• CCP
• Remaining hazard = unacceptable risk?
• Critical Control Point
 Control limits
 Monitoring procedure
 Corrective action
 Verification
 Recordkeeping
Manufacturing
facility
GMP
mitigation
Hazards to
product
Mitigated
product
hazards

11. Incoming resin hazards
SAFETY HAZARD CATEGORY
Biological?
Chemical?
Physical?
GMP INDICATED?
Pathogens killed at extrusion temperatures. *
Regulatory composition
 Contaminates filtered out at screen pack
* Good hygiene practices still needed post-extrusion

12. Suitable purity (supply chain integrity)
Substance
Raw
material
Article
Food
Supply
Chain

13. II. Management systems rules
Command & control model Contract law model

14. Rules of management systems
Command & control model Contract law model

15. Rules of management systems
Firstly, do no harm Comply with all relevant laws

16. 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

17. 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”

18. Contract law model for societal optimum
Economic
System to
deliver
diverse/low
cost goods
to public
Environmental
Material &
energy
efficient
Delivery
system
Social
Reliably
safe &
nutritious
food
Sustainable Business Model

19. Retailers: “biggest skin in the game”
Supplier Processor Retailer Consumers

20. 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

21. 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

22. Packaging: liability multiplier
Multi-layer film:
$100 k
Filled packages:
$4 million
Retail packages:
$7 million

23. III. Management systems enforcement
Securities and Exchange Commission Certified Public Accountants

24. 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.

25. Safe
food
Supply chain
integrity
Public well
being ($ , )
Complimentary food safety roles

26. IV. Management systems expectations
1. Scheme owners “benchmark” their system to the GFSI guidelines
1. BRC
2. SQF
3. IFS
4. FSMS 22000
2. “Certifying Bodies” (CB) obtain license to audit to the system
1. Auditors have specific training to the scheme and for auditing activities
2. Auditors have relevant industry experience and/or training
3. Manufactures hire a CB to audit their system
1. “Evidence”: ongoing management of food safety system practices, elements, commitment
2. Much more than housekeeping inspection

27. 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

28. Conclusion
Food packaging can pose risks to food
Command & control model has limits
$takes can be high
Contract model complements command & control
Contract model targets continuous improvement
3rd party certification compares to financial audit
Align organization toward food safety
Public
Health
Supply
chain
integrity
Societal
Optimum

29. Thank you!
Questions?