Advice on implementing a food packaging safety program

Beginning the process for understanding and implementing best food packaging safety practices requires clear communication, risk level determination and identification of expectations.

Best practices and their application are highly dependent on the position of the user. One is either a customer, requiring food packaging suppliers and vendors to apply and prove satisfactory conformance with current best food safety practices, or a recipient of said requirements by a customer or their representative. Regardless of whether you are the initiator of compliance or a supporter thereof, you need to understand the definitions and reasonable expectations of the programs, processes, and steps you are instructed to use within said context. Discussions with your direct (either upwards or downwards) supply chain partner will help illuminate, clarify, and confirm your understandings and interpretations of the required best practices.

Like everything else in a business relationship, agreement and effectiveness evolve from cooperative and meaningful two-way communication.  While typical GFSI (Global Food Safety Initiative) and other comprehensive food packaging safety expectation manuals are written in detail, some objectives may be open to interpretation. It is entirely possible that your partner has an understanding of the meaning of one or more specific precepts within the targeted expectations manual (assuming the initiator has defined a particular program target) that is inconsistent with your understanding, interpretation or perspective. It is also possible that each of you is basing your performance on guidance from qualified, but disagreeing subject matter experts or that a step or objective is partially but not fully attainable in a timely and cost-effective manner.

Reach an agreement on risk level

Before getting into the details of complying with individual expectations, supplier, customer and/or supply chain partners are well-advised to come to an agreement on a risk level. Often, the customer assigns a risk level (high, for example), which the supplier finds unreasonably onerous and unnecessary to ensure food safety. The supplier may have concluded that his/her components and related supply chain are low or medium risk, not high. In that case, the onus is on the supplier to research broadly accepted definitions for “high, medium, and low risk” materials and provide the customer or initiating party with a written report describing how and why their assessment of the risk level is incorrect. Naturally, that report needs to be compelling, with the situation-analysis accurately described, researched and justified, containing arguments and contentions that are supported with facts, examples, and validated conclusions.   

A two-step arbitration

In cases of disagreement, I suggest that the subservient or aggrieved party initiate a two-step responsive approach. Begin by creating a list of sponsor requirements that you judge onerous, unnecessary, inapplicable or unclear. Request clarifications, additional explanations, examples or detail from the sponsor representative.  After considering all pertinent sponsor information and guidance, create a written list of requirements or expectations with which you disagree. Utilize qualified internal and external resources to comprehensively research and explore each item individually. Next to each one, add a short description of the overall purpose and objective and, separately, a summary narrative of the execution that your organization is capable of performing and how it satisfies the requirement’s broader objective.

Trained, responsible quality professionals are taught to listen to auditees and take reasonable mitigating hardships and circumstances into consideration before rendering arbitrary (negative) decisions on non-conformance. Creating, providing and explaining your specific plan to meet the broader objective sends a message to the sponsor that you take the issues seriously, have thought them through, commenced implementation and are providing evidence to demonstrate or prove effectiveness. Sponsor and partner disagreement based on arbitrary requirements, undeveloped detail and an intended or perceived unwillingness to compromise is an expensive, resource-draining and ill-advised pursuit which benefits neither.

Once sponsor and customers or partner(s) are on the same or similar page regarding risk, expectations and mitigation, performance strategies become easier to create. Alternatively and obviously, moving forward in secrecy and disagreement without cooperative communication culminates in the probability of misalignment with the program and acrimony between the affected parties. 

Next month: Considering and Categorizing Risk and Its Relationship to Food Packaging Safety Expectations    

Gary Kestenbaum has 40 years’ experience in the food and packaging industries, six as a supplier with National Starch, 18 as a product developer with General/Kraft Foods and 15 as a packaging engineer and developer with Kraft. In his current position as Senior Food Packaging Safety Consultant with EHA Consulting Group, Kestenbaum provides guidance on packaging safety and suitability-related projects for raw material manufacturers, converters and associated supporting professionals. He can be reached at [email protected] or 410-484-9133. The website is www.ehagroup.com.