Principal Chemist - Food Packaging
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Smithers expert Tony Lord provides an overview on how an independent audit of your waste material process can help companies demonstrate compliance with safety regulations and support with their quality process.
The audit process involves following a lead auditor style approach to check that a quality system is in operation. Examination of the quality manual and process documents allows a judgement to be made on whether the process is maintained within control and subject to continuous improvement. The site is then inspected and finished batches selected either at random or as a result of observations on the process floor. These are then tracked back through their documentation to the original waste stream delivered to site. The documented information is cross referenced against observations from the site inspection and process generated data. The documentation is checked to establish the origin of the input waste as an indication of likely original compliance of the waste against Regulation (EU) No 10/2011 as amended.
Checks are made to ensure that less than 5% non-food contact waste is being processed. Critical control points are checked. This allows the client to demonstrate that the recycled product complies with Regulation (EC) No 282/2008. Key analytical data are examined to confirm that composition quality is consistent and not of a variable nature dependant on fluctuations in input waste material.
The audit identifies potential areas of improvement. It also examines the corrective actions taken in response to audits under the quality standard that the recycling site is working under. This allows corrective actions to be taken or alterations in working processes to be made in advance of quality standard audits. This helps to ensure that the Quality System covers the objective of producing recycled product compliant with Regulation (EC) No 282/2008.
All sites operating the first stage sorting and washing process as well as those operating the second stage decontamination process for which a valid application to EFSA is required.
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