By Jeannette Sweigart and Nuno F Soares
There is a new buzz among food packaging manufacturers—How to manage allergen(s) when shipping materials are sent back from manufacturers who facilitate declared allergens. Third-party auditors are noticing a rise in returns of dunnage and appropriately are asking questions.
Let us share a true story. As a plastic bottle manufacturer, controlling allergens was as easy as requiring employees to wash hands after eating. Then one day, returned empty boxes from a food manufacturer were found to be coated with mustard smears upon inspection. Suddenly, cross contamination of allergens was on the receiving dock. Now what do we do? And how do we manage those allergens?
Dunnage, corrugated cartons, trays, pallets, and other shipping items are often sent back to the packaging manufacturer for reuse. This return program is viewed as a cost saving and is also good for the environment. It is estimated that return packaging may grow from less than five percent to approximately 20 percent in the near future.
Influencing factors such as negative environmental impact are not expected to diminish significantly anytime soon. Several governments are developing policies to promote a global circular economy. An increasing number of potential situations where materials are reused and allergen cross contamination may occur is also expected.
How to Address The Problem
Before packaging manufacturers accept returnable packaging, they must consider if this practice could introduce allergens into their facility. For that, the best option is to require clients to provide a declared allergen list. This list should include steps to control said allergens and be followed by a visit to the client’s facilities, understanding their processes, and looking closely at the flow patterns of the packaging that will be returned. This means that not only the packing itself (after being used) and the place of storage should be monitored, but also where the packaging flows inside the client’s facilities and which food products it maybe in contact with. The first step is to work closely with the client to prevent or minimize contamination of the returnable packaging with allergens. For that, it should be considered to examine client’s risk assessment on allergens and/or even the packaging manufacture should perform its own allergen risk assessment at the client’s site.
Another important aspect—Is the packaging is washable? Can the clients cleanse the packaging with efficient processes? Checking these issues should be another point to include on the checklist when visiting the client. Certainly, when reusable plastic pallets are returned, this program should be considered an option to eliminate the risk of returnable packaging carrying allergens back to manufacturer facilities.
In the case of unavoidable contamination by allergens, procedures must be put in place to validate if cleaning procedures (when applicable) are efficient in removing allergens or to verify if other control measures are achieving the intended results. For that, swab tests to detect the presence of allergens are a great option to consider.
Before we go in more detail, we would like to present a diagram that can be of guidance regarding how to manage this issue.
Figure 1 – Managing allergens in returnable packaging
Requiring a letter to guarantee that the packaging returned is free from allergens is the simplest option of all. Despite that, the core essence of a food safety professional is to guarantee that people can eat the food products without getting sick. This does not mean guaranteeing that responsibility can be addressed by another stakeholder. So, in case of doubt or lack of confidence, the better option is for the packaging manufacturer to take charge of the responsibility of controlling the hazard. That being said, letters of guarantee may still be used and retained as important records of any food safety system.
Another option is to settle an agreement that the client should control the presence of allergens either by washing and monitoring efficiency and/or by controlling allergens prior to returning to the packaging to the manufacturer’s facilities.
The last option requires more effort from the packaging manufacturer since the cleaning and/or control of allergens is their responsibility. In fact, even when a packaging manufacturer opts for one of the other options, especially if only for the letter of guarantee, it will be recommended that some verification is done internally, such as swab test.
Choosing one of these options or even using them all would be something that the packaging manufacturer should consider according to risk assessment conducted on the client’s site. In the next section, different solutions are presented for different scenarios. (Each food safety professional should look at the particular circumstances of its organizations and clients and decide the best options. The solutions provided are only hypothetical).
Addressing this issue will no doubt require a time and money investment. The overall cost will depend if the preventive control is made on the client – or manufacterer’s side and if the services of an outside lab are required. In market swabs designed to screen the presence of allergens can be a great tool for procedural validation and control.
So that you can see that the different options can be used alone or in combination according to the circumstances, here are examples of different scenarios and what can be done in each of them.
1. New client
In the scenario where no historic performance information from the client is available, the preferable option is for the manufacturer to control the presence of allergens. Consequently, when a supply agreement is settled, one of the clauses should assign the responsible party. Even when it is settled that the client is responsible, at least on the first two to three purchases, the packaging manufacturer should verify incoming returnable packaging for allergens by swab test. It is strongly suggested that a visit is conducted at the client’s facilities to verify their allergen management practices and programs prior to reducing or eliminating the internal control.
2. Long-time client
If the client has worked with the packaging manufacturer for a long period of time—where trust has been built on a history of no contamination to returned packaging and continued verification activities at their facilities—this may be the perfect scenario where the use of only a letter of guarantee is viable. Even in this scenario, the client may consider routinely sharing current records associated with allergen management/control.
3. GFSI certified client
If you have a client (new or long-time) that is GFSI certified the necessity of a visit/audit of the client may be reconsidered. In this case, having a letter of guarantee and information when they have some issue related with allergen control (e.g. via review of audit records) may be enough to manage allergens presence in returnable packaging. Nevertheless, these organizations may be included in a routine check with periodicity depending on historical performance.
4. Non-food client
It is worth mentioning that food packaging manufacturers frequently are diversified selling to food and non-food clients. Can you hear the questions a third-party auditor would ask about a non-food client? Have you been to the client’s facility? Does your client have a pest control program? Does your client have harmful chemicals that could cross-contaminate your plant? Have you completed a risk assessment? Ultimately, you must take into consideration the hazards which can be introduced by non-food client return dunnage and likely implement controls that are no different from the ones implemented for food clients.
The issue of allergen control enforcement on returnable packaging is probably still under the radar of many food safety professionals. But that’s about to change. This problem is increasingly being raised during third-party audits and is better that organizations have systems in place to prevent this industry’s process allergen contamination before any auditor asks for it, right?
There is no definitive solution that can be used in all situations. Food safety professionals must make decisions based on risk assessment, verification activities, and their knowledge and trust of the client’s ability to provide truthful information and efficient control. Food safety is by principle preventive. So before we start jumping into extra costs by acquiring swabs or sending samples to the lab, be sure to join efforts with clients in doing all that is possible to prevent allergens from reaching your facilities in the first place.
About the authors
Jeannette Sweigart has worked in quality management for more than 15 years in the food packaging industry. She has led six North American manufacturing sites to successful FSSC 22000 and ISO 9001:2015 certification. She is also a certified FSSC 22000 and ISO 9000 lead auditor.
Nuno Soares is a food engineer who has been working in food industry since 1999. Nuno has worked in roles including quality and production manager. With the goal of reaching further with his ideas for food safety and support other professionals in their daily work, Nuno recently embraced researching and publishing activities. For his PhD, he researched how to improve frozen fish shelf-life and protection by developing a new glazing solution. After publishing his first book Food safety in the Seafood Industry (Wiley), he recently self-published the e-book: ISO 22000:2018 Explained in 25 diagrams.
You can contact Nuno on LinkedIn or at www.nunofsoares.com.