Waste food packaging can result from different situations within a food business. What we do or don’t do with this type of waste can impact our ability to minimize both our food safety and business risk. Read on to find out some examples of waste food packaging, how to dispose of it correctly and what your compliance obligations are.
Examples of Waste Food Packaging
Before we jump into the why and how it is good to understand what may constitute waste food packaging. Here are a few examples:
- Pre-printed packaging or labels that contains the wrong information
- Labels that you print onsite that are illegible
- Packaging removed from returned or recalled food product
- Packaging that has become contaminated with dirt, dust or other environmental hazards
- Damaged packaging observed on receival or within storage areas
- Packing machine changeover or breakdown off-cuts
- Unused or excess packaging due to updated or new product runs
Take a moment to think about where waste food packaging can be generated in your food business.
Why does it Matter?
One of the most common causes of product recall is the mislabelling or mispacking of food product. When incorrectly labelled or printed allergens are involved, the risk of harming allergic consumers greatly increases. This alone should motivate your food business to effectively manage and control its packaging materials.
So, in saying this, one of your primary food safety goals should be to prevent the inadvertent use of packaging that is printed incorrectly. Another key aspect is to control the use of obsolete or contaminated packaging. These all tie into making sure that your product is both safe and legal.
When I worked as a government food inspector there was a recall of product due to potential contamination. We later found this product for sale on the shelves of discount stores. The recalling company had not effectively disposed of the contaminated product.
In another example, expired product was dumped into an unsecured ‘skip-waste bin’ only to be removed and consumed by freegans, AKA, dumpster divers.
The majority of GFSI recognised certification programmes and third-party customer standards have requirements for the disposal of waste food packaging. Lets’ look at some examples.
- BRC Global Standard Food Safety (Issue 8) – 5.5 Product packaging requires procedures for the disposal of obsolete printed materials to make them unusable. Clause 4.12.3 also touches on secure waste disposal.
- SQF Manufacturing (Edition 8) – 11.9 Waste disposal requires the controlled disposal of trademarked materials. Similar requirements are also listed in clauses 126.96.36.199, 188.8.131.52, and 10.8.1.5. SQF Fundamentals (Edition 8) requires written procedures for the disposal of unusable packaging and trademarked material. You can read more in clause 184.108.40.206 and 11.9 Waste Disposal.
- IFS Food (Version 6.1) – 4.11 Waste disposal does not get specific per se on disposing waste food packaging securely but does require waste to be disposed by authorised third parties only.
- WQA Manufacturing (Version 8) – 2.7 Security Protocols requires procedures for the destruction of discontinued and obsolete WW branded product or packaging.
- ISO 22000 (2018) does not make specific reference to waste food packaging however there are requirements listed in 220.127.116.11 – Disposition of nonconforming products, which touch on the destruction of products that are not acceptable for release.
Your chosen compliance standard may have similar requirements listed in sections or clauses related to non-conforming products.
Secure Destruction and Disposal Methods
The purpose of effectively destroying and disposing of waste food packaging is to prevent its inadvertent use. It is also to prevent others outside of your business doing the same. The best way to do this is to make the waste packaging unusable. You can do this in a few ways.
- Shredding waste labels or packaging works well when dealing with small quantities.
- Use a third-party contractor to remove and destroy waste items when you have large quantities.
- Remove all packaging from recalled or non-conforming food products (if feasible) prior to disposal. If this is not possible, make sure that evidence of destruction is available or verified.
- Redact information on waste labels or packaging that will make it clear that the items are not usable.
Whatever method you choose ask yourself “could someone accidently or purposefully now use this packaging”.
Third-Party Waste Removal
The use of third-party waste destruction was mentioned above but I want to expand further on this. In this situation verification of destruction and disposal is key. Make sure that have evidence to support effective destruction on disposal.
In my business all my confidential paper waste is shredded by an external contractor. They arrive onsite with a ‘paper shredding truck’ and do it on the spot. They then provide a certificate of destruction.
Have your say
How do you dispose of your waste food packaging? Do you have procedures written on how packaging destruction occurs in your food business? Share your knowledge, thoughts and experiences with the HACCP Mentor community by leaving a comment below.