Packaging Materials

Q. If harvested product is stored in harvested product packaging materials and these are used to store equipment after they are empty – is this acceptable? What if adjacent harvested product packaging materials still contain product? They would be separated only by wooden walls.

A. Section 17.2 Use of Packaging Materials states for Harvested Product Packaging Materials that producer/packer uses materials that are clean and free of debris (e.g., from other crops, compostable waste, garbage) and have not been used for any other purpose that may be a source of contamination (e.g., to carry tools, personal effects, cleaning agents, agricultural chemicals, maintenance materials or previously used to harvest other crops where agricultural chemical residues may contaminate product). Therefore, it depends on what type of equipment and if it is a source of contamination (e.g., leaking oil, lubricants, etc). Also, Section 20.1 Storage Conditions for Harvested Product requires that harvested product is in an environment that does not contaminate the product or the containers they are in (e.g., clean and well-maintained storage area) and is separate from market product, equipment, fuels, agricultural chemicals (including treated seed) and market ready packaging materials. The definition of separate is not on top of or underneath. Therefore, it is acceptable that these are in the same area as long as they are not a source of contamination to the product (e.g., leaking oil from the equipment etc.)

Q. A packer puts a blue sticker with an X on it (in his records this indicates it was packed during the week of April 7-14) and writes 'PJ' (in his records this represents a producer named Paul Jones) on his secondary packaging materials. Has the packer fulfilled the requirement for PACK ID?

A. Yes. The definition in the glossary of Pack ID is the following: “Information identifying the producer and when the product is packed. Linked to Lot ID for complete traceability”. The producer in this case is Paul Jones. The product was packed during the week of April 7 -14 which fulfills the requirement for when it was packed. This does NOT have to be a date. It is up to the packer to determine the “when” – it may be an hour, a week, a month, etc. It is however, in the packer’s best interest to narrow down the “when” as in the case of a recall the least amount of product affected the better. Section 17.2 Use of Packaging Materials requires that the Pack ID be on the secondary packaging materials unless there are no secondary packaging materials then it would be on the primary packaging materials. If there are no primary packaging materials, then the Pack ID would be on the pallet or skid.