Harvested Product Packaging Materials
Section 17.2 (Use of Packaging Materials) states for Harvested Product Packaging Materials that operations use 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 is being stored in them 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, underneath, or touching”. 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.).
Market Ready Packaging Materials
An operation that is packing puts a blue sticker with an X on it (in their records this indicates it was packed during the week of April 7-14) and writes ‘PJ’ (in their records, this represents the initials of the owner of the operation that produced the product) on their secondary packaging materials. Is this fulfilling the requirement for Pack ID?
Yes. The definition for Pack ID in the glossary is the following: “Information identifying 1) who produced the product and 2) when the product is packed/repacked. Linked to Lot ID for complete traceability”. The person who produced the product in this case is Paul Jones (PJ). 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 operation to determine the “when” – it may be an hour, a week, a month, etc. It is, however, in the operation’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.
No, in this situation the operation would not be required to have the Pack ID on the boxes. The requirement in Section 17.2 (Use of Packaging Materials) requires a Pack ID on market ready packaging material under the assumption that the operation is not able to put it on the actual product. If this information is on the actual product, this is even better for traceability and fulfils the requirements.
As per Section 17.2, the box would still need to be labelled [unless the secondary container is transparent (e.g., a large clear plastic bag holding smaller labelled bags of carrots)] with the correct identifying information (i.e., name and address) of the operation that produced the product, OR the operation that packaged the product, OR the company for whom it was produced/packaged. This is a requirement as well as a federal regulation.