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Kraft Foods Supplier Quality and Food Safety

Forum
Kraft Foods Supplier Quality
Expectations - Packaging Suppliers
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Objectives of the Kraft Foods Supplier Quality
and Food Safety Forum
Meet Kraft Foods team
Gain insight into Kraft Foods supplier quality
programs
Learn about changes to Kraft Foods supplier quality
expectations
Understand the HAACP Program and key program
changes
Obtain clarity on Kraft Foods expectations through
Q&A
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Kraft Foods and Cadbury: Building a Global
Powerhouse
$48B in Combined Revenue, Driven by 11 $1B + Brands
Presence that's global..
Worlds second-largest food company
#1 in North America
#1 in confectionery and biscuit
Sales in ~160 countries
25%+ of global revenue from emerging markets
Over 70 $100MM+ brands
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Introduction
Kraft Foods Supplier Quality Expectations
INTRODUCTION
PACKAGING EXPECTATIONS
QUALITY SYSTEM CONTROLS
FACILITY ENVIRONMENT CONTROLS
PRODUCTION PROCESS CONTROLS
INCIDENT MANAGEMENT
Kraft Foods Supplier and External Manufacturer
HACCP Manual
Q&A
Agenda Topics
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- Kraft Foods Supplier Quality & Food Safety Overview & Kraft Foods
Supplier Audit Program
- Kraft Foods Material Monitoring Program & COA Requirements
- New Kraft Foods Raw Material Specification Requirements & Process
- Kraft Foods Supplier Quality Expectations (SQE)
Kraft Foods Supplier Quality Expectations - Packaging Suppliers
To be determined
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Completed in 2009-2010
Upcoming
Today
Supplier Forum Program Overview
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Monitoring
Policy/Contract Requirements
Continuous Improvement Selection/Approval
A comprehensive approach to managing supplier quality
- Supplier QI Program
- Supplier Quality Partnerships
- Supplier Development
- Supplier Forums
- Industry Benchmarking
- Quality Policy
- WW Supplier Quality
Expectations (SQE)
- Supplier HACCP Manual
- Material Specifications
- WW Quality Audit Program
- Materials Monitoring Program
- COA Verification
- Supplier Performance Monitoring
- Certificate of Conformance (COC)
- Risk Assessments
- Supplier Pre-Assessment
- Quality Audit Approval
Supplier Quality Management
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Old Format May2010
SQE (12-Feb-2008)
Packaging SQE
(23-Jun-2005)
SQE (including
packaging)
main information
SQE Resource
Document
detailed information
supplementing the base
manuals requirements.
Supplier/EM
HACCP Manual
Supplier HACCP Manual
(12-Feb-2008)
Packaging SQE
(HACCP Chapter and CCP
Models) (23-Jun-2005)
Must be sent to the
suppliers.
Suppliers will be audited
against these
requirements.
SQE Appendix
(12-Feb-2008)
Format and content were reviewed for simplification
SQE Updates - Overview Format/Content Changes
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- Why we need the Supplier Expectations?
The safety and quality of our products are of the highest importance to us -
- as are the trust and confidence of our consumers and customers. At Kraft
Foods, we inspire trust by making safe food.
The expectations outlined in the Supplier Expectations are intended to help
Kraft Foods meet this objective by making our quality standards clear.
These expectations have been developed by Kraft Foods after a review of
product defects, quality audits of manufacturing sites and a study of
product retrievals throughout the food industry.
This review led Kraft Foods to identify which programs, if executed well,
would helped to prevent product retrievals, consumer complaints,
rework and plant downtime.
SQE - Introduction
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- Scope: Ingredient, Commodity and Packaging Suppliers
- Brokers, Distributors and Traders
Ensure the Kraft Foods SQE Manual, Supplier HACCP Manual and Kraft
Foods Specifications are communicated to suppliers and provide
evidence of agreement to requirements by the supplier.
The broker/distributor/trader has responsibility to ensure that supplier
complies with SQE requirements.
The broker/distributor/trader is required to notify Kraft Foods of
any manufacturing location changes. New sites must be approved
by Kraft Foods prior to use.
The broker/distributor/trader must demonstrate that traceability of
materials to manufacturing location level is maintained.
SQE - Introduction (cont.)
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- The Supplier must immediately notify Kraft Foods of occurrences which
could affect the processing, food safety or quality of materials supplied to
Kraft Foods. Additional occurrences:
Inadvertent release from Hold of any material produced for Kraft Foods.
Notification by law enforcement or other authority of a potential product
security event.
Identification of an unlabeled allergen on material produced for Kraft
Foods.
Inability to deliver materials that meet Kraft Foods Specifications.
Changes to suppliers processes and/or facilities that could have an
impact on materials supplied to Kraft Foods.
SQE - Introduction (cont.)
Packaging Type SQE Sections Not applicable to
Packaging Suppliers
-Food Contact Packaging and/or
-Contains Ingredient Line or
Legally Required Information
Section 3.10 - Zoning
Section 3.11 - Pathogen Environmental Monitoring
Section 4.10 - Weight Control
Non-Food Contact and Does Not
Contain Ingredient Line or Legally
Required Information
Section 3.5 - Utilities Management
Section 3.10 - Zoning
Section 3.11 - Pathogen Environmental Monitoring
Section 4.2 - HACCP
Section 4.6 - Allergen Management
Section 4.8 - Rework Control
Section 4.9 - Label Control
Section 4.10 - Weight Control
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SQE - Packaging Requirements
All packaging materials supplied to Kraft Foods must comply with all
applicable laws, regulations, and Codes of Practices and Standards of the
production country and the destination to which the materials will be
delivered.
All food contact materials shall be accompanied by a declaration of
compliance covering materials and conversion (e.g., inks, adhesives,
coatings).
Where no dedicated national food packaging legislation for plastic
material exists, Kraft Foods requires compliance with the European or the
U.S. federal and state regulations:
- Food and Drug Administration (FDA) (21 CFR),
- U.S. Department of Agriculture (USDA),
- U.S. Environmental Protection Agency (EPA).
SQE - Packaging Requirements (cont.)
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- Transfer of constituents from a food contact material to food
Packaging materials that come in direct contact with the product, either
by design or by foreseeable use, are defined by Kraft Foods as Primary
Packaging.
Materials shall not transfer their constituents to foodstuffs in quantities
that could:
- endanger human health,
- cause an unacceptable change in the composition of the foodstuffs,
or
- result in deterioration of the organoleptic (tainting) characteristics
thereof.
- Packaging Hygiene
Food Contact Packaging shall not be a source of biological (e.g. microbial),
chemical or physical (e.g. foreign bodies) hazards.
Suppliers must demonstrate their ability to control food safety hazards in order to
ensure that food is safe at the time of human consumption.
SQE - Packaging Requirements (cont.)
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- Recycled post consumer material
Kraft Foods favors the use of recycled materials provided that strict
requirements are established to ensure food safety.
Food contact packaging material suppliers (except for those exclusively
supplying glass and/or metal) shall have a system in place to notify Kraft
Foods of any products or materials supplied to Kraft Foods that contain
post-consumer usage recycled material.
Kraft Foods typically does not permit post-consumer recycled materials
(except for glass and/or metal) used for primary packages to come in
direct contact with food, unless Supercleaned processed.
Exceptions for specific product applications can be agreed to by Kraft
Foods and must be included in Kraft Foods Packaging Specifications.
- Printing Inks and Adhesives
Printing inks applied to the non-food contact side of a packaging shall
not transfer any residues of toxicological concern.
The inks must be of appropriate purity to ensure that there is no
migration of substances that have not been toxicologically evaluated and
that there is no violation of any specific migration limit imposed for other
materials.
SQE - Packaging Requirements (cont.)
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- Packaging Material Ingredients and Processing Aids derived from
Allergenic and Genetically Modified Sources
Materials derived from allergenic sources shall not be used. Allergenic
sources are defined in the Kraft Foods Allergen Category List (see
Appendix C of the Kraft Foods Global, Inc. Supplier and External
Manufacturer HACCP Manual).
Kraft Foods must be notified of the use of rubber-based natural latex
used in adhesives or other indirect potential contact applications, as well
as the use of any materials derived from Genetically Modified sources
(GMOs).
- Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH) - only applicable for EU
Compliance with REACH Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH) for all packaging items that are preparations or articles
containing substances to which the REACH obligations relate.
SQE - Packaging Requirements (cont.)
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SQE - Packaging Requirements (cont.)
-Packaging Component Information Sheet (PCIS)
For all packaging materials produced or shipped to the U.S. or Canada, a
Packaging Component Information Sheet (PCIS) must be obtained from the
Kraft Foods Contract Representative, completed and returned to Kraft Foods.
A process for Europe, Latin America, Asia Pacific, Middle East and Africa is
currently under development and will be implemented in Q4-10/Q1-11.
-Regulatory references and methods
A non-exhaustive list including:
- Packing material criteria,
- Specific US, EU and national regulations, legislations and guidelines,
- Testing methodology.
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- Quality Management System and Documentation
The Supplier shall develop, implement, verify and maintain an effective
Quality Management System for the design, manufacture and delivery of
safe, consistent and high quality products.
- Internal Audits
The Supplier shall establish and maintain written procedures for conducting
internal audits to implement, verify, and review their Quality System.
- Regulatory Inspections and Contacts
Requires documented procedures and designated, trained personnel in place
for the management of Food Regulatory Agency inspections and contacts.
In the event a regulatory agency samples material produced for Kraft Foods,
Kraft Foods shall be immediately contacted.
- Testing Controls
Testing and monitoring programs shall be based on official test methods or
test methods that have been validated by Kraft Foods for their intended use.
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SQE - Quality System Control
- Kraft Foods Audit/Inspection Requirements
All facilities producing packaging materials for Kraft Foods must be approved
by Kraft Foods.
Packaging materials that touch product or include an ingredient line declaration require
an acceptable audit.
Allow Kraft Foods or 3
rd
Party quality auditors or their representatives to enter and
audit/inspect at reasonable times any establishment storing or supplying for Kraft
Foods.
The audit/inspection may include review of records, processes, controls, equipment, and
facilities. The audit/inspection shall be not be extended to financial data, sales data,
pricing data or personnel data.
Suppliers will be notified of the specific audit requirements for the materials to be
purchased by Kraft Foods at the time of scheduling the audit. Kraft Foods will bear its
own internal costs and the Supplier will bear all other audit costs (including those of the
third-party auditors).
Audit findings must be deemed acceptable by Kraft Foods to become or remain an
approved Supplier.
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SQE - Quality System Control (cont.)
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SQE - Quality System Control (cont.)
Food Defense Food Defense
Definition: Taking steps to safeguard the food supply against intentional
acts (or the threat of an act), such as a mass contamination or product
tampering.
Site Food Defense Plans are designed to protect the supply chain from
intentional contamination.
Four basic requirements of a good plan:
1. Program administration (documented plan, defined role s & responsibilities,
annual vulnerability assessment)
2. Access control
3. Background screening (subject to local law)
4. Shipping and Receiving (monitor and verify the integrity of incoming and
outgoing shipments).
- Food defense is a critical effort towards safeguarding our
products.
- We continue to expect Kraft Foods facilities and suppliers alike to
help secure the food supply for the good of our businesses and
our consumers.
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SQE - Quality System Control (cont.)
Food Defense Food Defense
It is now mandatory for suppliers in all Regions to have a
food defense plan that meets the 2010 SQE requirements.
By early October of this year, select suppliers will receive a short
survey about their site specific food defense plans with a goal of
improving the overall program. Others will receive their surveys in
the coming months.
We are in the process of aligning a 3
rd
party verification process in
which all suppliers will eventually need to participate. The
verification process will identify needed improvements in supplier
site plans.
Third party certifications can be a good tool for creating food
defense plans but are currently not a substitute for having a plan
that meets the new SQE requirements.
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- Good Manufacturing Practices
All personnel entering the Supplier facility (plant personnel, visitors and
outside contractors) shall comply with GMP requirements.
- Personnel Training
The Supplier shall ensure that all employees receive appropriate training for
their job functions.
- Employee Illness and Communicable disease
The Supplier shall establish written instructions for the control of employee
illness and communicable disease that may result in pathogen transmission
by food.
- Plant Structure
The facility shall be of adequate design and construction to ensure
production of safe and high quality materials.
The Supplier shall ensure that the facility is satisfactorily
maintained.
- Utilities Management
The Supplier shall have implemented programs to ensure safe provision of
Utility Services in production areas. Utility Services include environmental
air, compressed air, water and steam.
SQE - Facility Environment Controls
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- Equipment Design & Validation
The Supplier shall ensure that equipment design is adequate for the
production of materials that meet food safety and quality parameters.
- Equipment Maintenance
The Supplier shall ensure that equipment and materials used for production
are suitable for the purpose intended and in good repair.
The Supplier shall have implemented a written program for preventive and
corrective maintenance that is up to date.
- Sanitation
The supplier must have a written and comprehensive plant and equipment
sanitation program.
- Pest management
The Supplier shall have implemented a written pest management program
to monitor and control pest activity in the facility and the surrounding area
effectively. Including:
- Documentation of pest activity, and analysis of records for trends in activity,
- Measures to prevent pesticides contamination of food contact surfaces.
SQE - Facility Environment Controls (cont.)
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- Specification compliance and Contract review
All materials supplied to Kraft Foods must have approved Kraft Foods
specifications .
Suppliers must consistantly deliver materials to meet these specifications.
- If the Supplier anticipates that it will not be able to meet the specification, Kraft
Foods Contract Representative shall be notified immediately.
- Incoming Materials
The Supplier shall buy materials only from suppliers who are approved
through a program designed to manage the quality of its own suppliers.
- Quality expectations, requirements and/or specifications for purchased goods that
are consistent with the programs in the Kraft Foods SQE Manual shall be
developed, documented, and provided to suppliers.
- Program shall include a risk assessment. Audit by company or 3rd party audits can
be part of that risk assessment. Feedback shall be provided to the suppliers to
facilitate continuous quality improvement.
The Supplier shall ensure that incoming product is not used or processed
until it has been inspected or otherwise verified as conforming to specified
requirements.
- Traceability
The Supplier shall have implemented a written program for product
traceability.
- If requested, such as in the event of a product recall or other product-
related issue, the Supplier must provide the relevant traceability
information to Kraft Foods within 4 hours.
SQE - Production Process Controls
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- Allergen Management
The supplier must inform Kraft Foods if there is any allergen that could be present in
the delivered material (e.g. by composition or by processing aid).
Supplier should inform Kraft in case allergen is present, and do all his best to limit /
eliminate that allergen.
Allergens to be considered by Kraft Foods
- Global & Regional Food Allergen Category List,
- Local regulatory requirements.
- Allergen Management (info printed on packaging)
Effective systems shall be in place to prevent mixing labels.
- Extraneous matter
The Supplier shall have implemented a written program to prevent, detect, and
control extraneous matter in material produced for Kraft Foods.
- The Supplier shall perform a risk assessment to determine potential sources of extraneous
matter.
- Based on the risk assessment, the Supplier shall develop an appropriate strategy for minimizing
extraneous matter.
- Appropriate and timely corrective action shall be implemented in case any source of extraneous
matter with potential of falling into the product stream is detected.
Periodic reassessments shall be conducted, particularly following changes to the plant
environment and instances of non-conformances (e.g. consumer complaints).
SQE - Production Process Controls (cont.)
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- Rework Controls
The Supplier shall have implemented a written program to control the use
of rework materials in any product supplied to Kraft Foods.
- E.g. rework in plastic component processing (extrusion, thermoforming).
- The amounts and identification of rework used shall be documented to ensure
complete traceability.
- Storage and Transportation
The Supplier shall have implemented systems to manage warehousing and
transportation to ensure that the safety, quality, and security of materials
and products is maintained at all stages from receipt of materials through
delivery of products to Kraft Foods.
SQE - Production Process Controls (cont.)
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- Hold & Release
Suppliers must have effective controls in place to prevent the inadvertent
movement of defective products or ingredients.
The Supplier shall have a written Hold and Release control program that
clearly establishes roles and responsibilities for effective implementation.
The program shall apply to product on the Suppliers premises or in third
party facilities used by the Supplier. The program shall include controls
for:
- non-conforming raw materials,
- materials pending testing, packaging and labels, semi-finished product
(work-in-progress), rework, and finished product.
The Supplier must maintain records sufficient to enable reconstruction of
each hold event.
The Hold procedure shall address at least two levels of Holds:
- Category I Hold - Shall be used when a non-conformity poses a
potential food safety concern or a major regulatory or quality concern.
e.g. Mixed labels
- Category II Hold - Shall be used when a non-conformity poses a
potential minor regulatory or product quality concern. e.g Foreign
material issue with no food safety concern
SQE - Incident Management
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- Product Retrieval
The Supplier shall have written retrieval procedures in place that promptly and
effectively respond to product issues that represent an unacceptable risk to
Kraft Foods and/or the consumer.
The retrieval system shall be tested on an annual basis and after any major
system changes to confirm (1) the accuracy of all product and contact data
and (2) the continuing effectiveness of procedures and traceability systems.
- Control and Disposition of Non-conforming product
The Supplier shall have written procedures for the identification,
documentation, evaluation, segregation (where practical) and determination
and execution of the final disposition of non-conforming products.
SQE - Incident Management (cont.)
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- Scope: Following packaging materials suppliers shall develop HACCP plans
consistent with this standard.
product-contact,
labels, and
labeled packaging materials.
- A documented HACCP risk analysis must be available for all products produced
for Kraft Foods.
Appropriate Prerequisite Programs must also be in place.
- For Packaging Suppliers, Kraft Foods has defined PCCPs.
These are Packaging Critical Control Points, which do not fulfill the Codex requirements
as limits cannot always be precisely defined and monitored.
The PCCPs given in the Appendix F, however, are not able to give evidence of every
production second, but are meant to draw special attention to certain processing steps.
Therefore they should be applied in the relevant areas to minimize the anticipated risk.
- Validation and Verification Process
Section that describes the verification process for determining that the HACCP plan is
accurate.
HACCP Manual - Requirements
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- Potential microbiological risks
The following list includes some potential microbiological risk areas
that must be reviewed concerning packaging material defects that
could lead to post-process microbiological contamination of
containers used for thermally processed or aseptically filled low-acid
canned foods (most of these hazards should be managed by one or
more CCPs in addition to appropriate Prerequisite Programs):
- Paperboard (primary packaging) manufacturing process-insufficient biocide during
pulping and paperboard-make process (most likely managed by a Prerequisite
Program vs. a CCP).
- Environmental post-process contamination of primary packaging material, e.g.
drips from roof leaks directly onto primary contact film or paperboard (most likely
managed by a prerequisite program vs. a CCP).
- Glass manufacturing-defects that would allow leakage (e.g. cracks, chips, dips in
finish).
- Cap manufacturing-insufficient or incorrect sealing compound on caps.
- Can manufacturing-can seam defects on the manufacturers end or inadequate
sealing compound.
- Film used for lids-defects allowing leakage.
- Retort cups-defects allowing leakage.
- Retort pouch-defects allowing leakage.
HACCP Manual - Requirements
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- Potential chemical risks
The following list includes some potential areas for chemical
risks that where possible shall be reviewed based on the
packaging material and the intended use by the consumer:
- Raw materials and processing aids used for primary packaging (product
contact or potential product contact) including printing inks, varnishes,
adhesives, etc. that release substances that can transfer from the packaging
to the food (e.g. migration or set-off).
- Raw materials used for packaging material or printing where the material
has a high probability of being ingested or put into the mouth (e.g. products
targeted for small children).
- Adhesives that have potential to contact food products (e.g. falling off of
carton into food when package is opened).
- Changeover from conventional packaging conversion to food packaging (e.g.
high purity demand of printing inks).
HACCP Manual - Requirements
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- Potential mixing labels risk
Manufacturers of labels and labeled packaging materials must include a risk assessment
and have controls in place for preventing or controlling the risk of mixing labels or labeled
materials (allergen/non-allergen labeling). Adequate controls must be in place at all points
of the label and labeled packaging material processes to assure labels are not mixed.
The following list includes some identified potential manufacturing errors (allergen
mislabeling):
- Incorrect label printing for allergen (printing or print copy error-allergen missing or incorrect)
- Mixing of non-allergen with allergen labeled containers, labels, film, or lids;
- Allergen and non-allergen labels printed on same printing plate/sheet (potential for mixing during
cutting, stacking, and sorting operations);
- Printed film spliced to different printed film (allergen/non-allergen) on the same roll;
- Labels or labeled packaging materials left in equipment and mixed at changeover (previous run mixed
with new run of different material);
- Partial pallets of labels or labeled packaging materials mixed with allergen/non-allergen on a pallet
- Case and/or pallet mislabeled.
Multiple systems may be required to assure adequate control. In some examples listed
above the identified risks could be controlled by use of vision systems or UPC Bar Code
scanners to identify potential mixing of labels or labeled materials. However, many of these
risks are the result of human error or equipment and process limitations and must be
identified and controlled. Controls must include strict employee handling procedures and
work processes that must be documented and performed by trained, accountable
employees. At a minimum, line clearance procedures at line changeovers or SKU changes
for label or labeled materials at line should be managed as a CCP or a Prerequisite Program
for most types of operations. Also, Cut and Stack Labels have higher risk of mixing due to
equipment limitations and optimization of print layout.
HACCP Manual - Requirements
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Summary
- The safety and quality of our products are of the highest importance to us -- as
are the trust and confidence of our consumers and customers. At Kraft Foods,
we inspire trust by making safe food.
- The Supplier Quality Expectations are intended to help Kraft Foods meet this
objective by making our quality standards clear.
- Key Changes:
Strengthening of communication requirements between supplier and Kraft Foods
- Change in manufacturing location supplying Kraft Foods
Food Defense requirements
Printing Inks and Adhesives requirements
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Kraft Foods Supplier Quality Web Site
- The Kraft Foods Supplier Quality web site is designed to facilitate the
communication between Kraft Foods and our suppliers. Here you will find
all of the Quality Requirements and Guidelines for Suppliers to Kraft
Foods, as well as the slides used in our Supplier Forums.
- The web site includes:
Supplier Quality and Food Safety Contractual Requirements
Supplier Forum presentations
Quality Support Material
Contact email address
- Browser Address: http://brands.kraftfoods.com/kraftsupplier/
Please share within
your company!!
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