At the very least, documentation for incoming packaging materials requires you to create a custom vendor/supplier disclosure form, the mechanism for obtaining component manufacturing disclosure and documentation.

Performing Step One as noted in the previous column, Food packaging safety: Risk identification, prioritization and response, must be complemented by Step Two: Obtaining adequate documentation.

At the very least, this requires you, the customer, to create a custom vendor/supplier disclosure form, the mechanism for obtaining component manufacturing disclosure and documentation. Regardless of what category the item is, as the next handler or user in the chain of supply, safety and suitability must be assessed.  Signed certificates (including allergens and contaminants, guarantees, compliances, regulatory, suitability, etc.) from your vendors are all required components of the documentation packet, but in the event of a crisis, you may need to prove diligence and awareness.  Assessing what you need to do to demonstrate diligence begins with requesting full custom disclosure of details from your vendors and suppliers and then reviewing and accepting the content, or as is more likely, reaching out to the vendor and requesting those items that were omitted or not properly prepared.

Review the content and format of each vendor disclosure document as if it were undergoing legal review; in the event of litigation or legal action, it will be reviewed by many professional eyes.  The primary benchmarks that the intake reviewer needs to consider during the review process is, “does this document represent or demonstrate diligence and accurate disclosure? When subjected to professional scrutinies, does it, within reason, function as protection for the corporation, or is it incomplete and dysfunctional”? 

Conclude, again, that lack of full and complete vendor disclosure (without the vendor risking genuinely valuable IP and trade secrets) transfers the risk to you in the event of a safety crisis.

Incoming materials risk mitigation and control

After the risk analysis team reviews the completed risk profile for each item, category or process in hand, including documentation, the next step is to determining how to eliminate, minimize or control that risk.  Best practices suggest or require (depending upon your products and their use) that one or more persons on the risk mitigation team be Hazard Analysis and Critical Control Points (HACCP) trained, in order to streamline and integrate the process of identifying, evaluating and controlling risk to food safety.  Not all risks involve harm to human safety, and a trained Quality Process and HACCP practitioner is most appropriately positioned to identify, categorize, prioritize and mitigate risks using HACCP plans, prerequisite plans or “other.” 

You, the readers of this column, represent a broad gamut of links in the supply chain.  Execution of risk identification and mitigation processes can vary by function (i.e. raw material supplier, converter, contract manufacturer, marketer, etc.) within the chain. Suffice it to say, though, risk assessment, if followed by effective mitigation and control, is best executed by professionals. The process begins with recognition or application of an effective, practical and comprehensive food safety program (GFSI or equivalent) complemented by one or more representatives (internal or consulting) adequately trained at the practitioner or subject-matter expert level, and who has the responsibility and authority to apply the precepts of food safety accordingly.  We will address and discuss additional risk priority categories in future installments of the column.

Next time:   Suggestions for risk response and control

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.