Brazil Notifies Food Packaging Good Manufacturing Practices to WTO
SAFEGUARDS | Hardgoods NO. 100/15
Brazil's National Health Surveillance Agency (ANVISA) has notified the World Trade Organization’s (WTO) Committee on Technical Barriers to Trade of a draft Technical Resolution, establishing Good Manufacturing Practices (GMP) for companies that manufacture direct-food-contact packaging (intermediate materials producers are exempted). All manufactures must comply with this regulation 18 months after its official release.
GMP  requirements are a fundamental part of the European Union to assure consumer’s health and prevent food contamination coming from food contact materials (FCM). Following this example, the Brazilian ANVISA announced its own requirements on GMP related to on FCM. The major points from the proposed regulations are highlighted below:
- Detailed requirements are laid out for the design of the buildings and facilities.
- Equipment, furniture and fixtures shall not release a toxic substance or odours and shall be kept in a clean and operational state.
- The factory must have a pest control program. Chemical pest control should be employed only when other preventive measures fail, and shall be carried out only by specialized companies, following specific legislation, using compliant products. Pre and post treatment shall take place to avoid contamination of packaging.
- The cleaning of the production area should be carried out on a predetermined schedule. The products used in cleaning operations must be regulated by the competent body. Odorant and deodorant substances shall not be used to avoid contamination and odour.
- Employees who present injuries or symptoms of illness that may compromise the sanitary conditions of packaging, equipment or environment should be removed from production work as long as the health conditions persist. Employees must wear a clean uniform that is appropriate for the work performed.
- The factory must have a sufficient number of dedicated waste containers which are easily cleaned, sanitized and moved. The waste shall be kept in a closed and isolated location away from production.
- Manufactures must specify the criteria for evaluation and selection of raw material suppliers. Raw materials shall be received in a protected and clean area. Inspection of raw materials shall be performed and results recorded upon receipt. Raw materials that fail inspection must be returned to the supplier. If they cannot be returned, they must be properly identified and stored separately with the final destination labelled. Any reusable scraps should be frequently collected and stored in an isolated, sanitary location away from production.
- During production, effective measures must be taken to avoid contamination of the product. For example, if water comes into direct contact with equipment, raw materials or final products, it shall meet the drinking water standard established by the Ministry of Health. The manufacturing process and the maintenance of equipment shall be documented. Quality control of the final product shall be performed to ensure the compliance to sanitary and health legislation.
- The packaging manufacturers must develop and implement a Manual of Good Manufacturing Practices that includes Standard Operating Procedures (SOP). The SOP shall be monitored and reviewed whenever necessary, and made available to operators and health authorities.
- The technicians responsible for the production process must be trained and have knowledge of hygiene and good manufacturing practices. While the production area employees must be trained at least the following subjects: the production process, hygiene, good manufacturing practices and knowledge of toxicity in the care and handling of raw materials and finished products.
- A check list is also provided for the implementation of GMP measures.
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