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What do Canadas new food-safety standards for packaging have to do with lubricants? A lot, it turns out.

If you supply lubricants to the food and beverage industry, or to the packaging industry, a customer may soon demand that your packaging must meet Canadas new food-safety standards for packaging, even when the products you supply arent food-grade lubricants.

The food and beverage industry for years has recognized the importance of HACCP (Hazard Analysis and Critical Control Point) food-safety standards. With growing attention to food safety and bio-security, the industry is now demanding HACCP compliance from its suppliers in order to control risk throughout the food chain. To meet this demand, Agriculture and Agri-Food Canada (the agriculture department of Canadas federal government) and the Toronto-based Packaging Association of Canada are developing standards for specific packaging materials based on HACCP principles.

HACCP is an international protocol to identify and manage risks in the food supply chain. Based on sound science, it focuses on identifying and preventing hazards from contaminating food. Extending HACCP to packaging means that packaging suppliers, their raw materials suppliers, distribution service suppliers and the buyers, fillers and users who specify materials will all be held responsible for ensuring that packaging materials do not compromise food safety.

Funded by the Canadian government and managed by the Packaging Association of Canada, the new HACCP standards are intended to enhance the quality of and increase foreign acceptance of Canadian food products. But the impact of these voluntary standards, begun in 2002 and scheduled for initial release in May, is expected to extend far beyond Canada, as global food companies adopt the requirements.

What PAC has done, said Elmer Eng, director of quality services at Bericap North America in Burlington, Ont., is gather representation from packaging suppliers, food customers and government to develop specific food-safety standards for packaging based on HACCP.

A New Standard

The standards have two parts, explained Larry Dworkin, PACs director of government relations and development manager for the standards. First is a generic prerequisite program applicable to all packaging material sectors. The prerequisites are common-sense programs of what to do around a plant, Dworkin said. For example, have more wash stations in the plant so employees can wash hands more often. Dont have a tree next to the plant – a squirrel could climb the tree and get into the plant.

The prerequisites are good manufacturing practices for packaging manufacturing, said Roger Miller, R.A. Miller & Co., Thornhill, Ont., who served as standards project coordinator through last year. They cover personnel, insect and rodent control, engineering and maintenance, outside premises, traceability and recall, and warehousing and storage, with specific requirements in each area.

The second part is standards tailored to the conversion of specific package materials. Were at the final stages of completing the HACCP standards for flexible and rigid plastic packaging and paper packaging materials, Dworkin said. They account for over 80 percent of all food packaging, and will be done by May, when our rollout across Canada is planned. Standards for glass and metals are to be completed by the end of the year.

The material-specific standards spell out the requirements for specific analyses to identify problem areas unique to the manufacturing process, that are not covered by the prerequisites, Miller said. The HACCP diagnosis process identifies critical control points, to remove food safety risks.

Youre in the Food Industry Now

One of the biggest concerns for food safety is label mix-ups, because of allergies, Miller continued. Wrong labels are also the big issue on small lube packages. Ensuring accurate labels is a big part of the packaging standards. For example, mislabeling is rampant in the corrugated industry, often traceable to changeovers from printing label A to label B.

Packaging plant people have to recognize theyre not in the box industry, theyre in the food industry. Think of the packaging plant as a kitchen.

For the lubricants packaging industry, compliance with the new PAC standards may present challenges. Under the standards, must food-grade lubricants come in HACCP-compliant food-grade packages? Absolutely! Dworkin replied. Food-grade lubricants must come in food-grade packaging. We cant afford the risks. Due diligence is required.

It will be a huge culture change for the lubricants industry, Miller noted. You start at the fence line and have different degrees of security. First, you try to stop the bugs at the fence.

In the lubricants industry, you cant sample packaging at a meaningful level, so you need to prevent incidents, Miller continued. The HACCP process is preventive, not corrective. You dont want recalls, so you prevent problems in suppliers plants to prevent incidents in your plant.

The Customers Voice

Kraft Foods requires that all primary packaging, labels and labeled-packaging suppliers have HACCP programs in place. SQE and HACCP requirements are included in purchasing contracts. Suppliers need to look at their packaging material as food contact. This may be a new concept for them, Debra Krug-Reyes of Kraft Foods Global told the PAC.

Nestle management is strongly committed to applying the … HACCP principles. In keeping with this approach to food safety, vendors to Nestle are required to have an effective HACCP system implemented, said Sandra Howe of Nestle Canada. Packaging vendors implementation of HACCP is as important as any other vendor within the food supply chain.

In the food safety/food production chain, youre only as strong as the weakest link. There are a lot of links from farm to fork. So you need to build on the weak links … Packaging is one of those links. … If you have a system in place like the PAC standard, then that shortens the amount of time we need to spend with you during our audit. … Its a paradigm change. Where you were used to doing things a certain way, we now need to move to more of a food safety focus. You cant resist it, said Parmalat Canadas Lorne Hietala.

When global food companies require compliance with HACCP food packaging standards, the packaging industry will pay attention. (And, noted Miller, Kraft are firmly but gently tightening the noose.) But the advantages of compliance go beyond keeping a global food company as a client, according to PAC.

Several HACCP provisions deal directly with bio-terrorism and security concerns, including measures such as product recall and traceability, site security and personnel access. HACCP compliance means greater exportability for products, and it can reduce insurance rates and liability. In the event of a personal damages claim, HACCP can be the basis for mitigating due diligence claims.

This program in Canada is leading edge, said Ron Sturk, president of APC Products, a supplier of plastic closures for dispensing liquids from pails, based in Brampton, Ont. The standards have benefits. We want to meet our customers requirements, and if they require it, well be in compliance. This would be a new program for us, but not much of a stretch.

Plastic closure manufacturer Bericap North America, one of the members of the PAC packaging standards steering committee, has been HACCP compliant since 2001, said the companys Elmer Eng. Bericap has implemented HACCP for all its product lines including food and beverage, and lubricant closures. The key benefit for lubricants is that contaminants are controlled with Bericaps closures. For our lubricant customers, they can be assured that there is no contamination, microbial, chemical or physical, that could affect a lubricants properties. Even non-food-grade lubricants can benefit. With todays engines and their tighter tolerances, oils and lubes need to be clean.

Whats Next?

PAC plans a nationwide training program for the new packaging standards after their release in May. PAC is producing manuals that will be available on CD in both English and French, Larry Dworkin said. For flexible plastics, one-and-a-half-day workshops are to be held across Canada, that packagers and their customers will attend. In Canada, were driving the program from the top down, going to the major food retail chains to start.

Then we want to export the knowledge to the U.S. and worldwide, Dworkin continued. PAC has been approached by organizations in 20 different countries. Nowhere else is there a similar program.

Why should the lubricant packaging industry get involved now? I recommend, do it now on your schedule, not when theres a gun at your head, Roger Miller contended. Its comparable to the auto companies and ISO. They required their direct suppliers to comply first, and then second- and third-tier suppliers. Start now. Its more affordable and doable when its self-managed. If you wait, the cost goes up.