ISE Magazine

JAN 2018

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36 ISE Magazine | www.iise.org/ISEmagazine Getting to good important to educate employees about how to think critically and how to make time-sensitive decisions such as when to notify a supervisor of a problem, when to halt production, when to consult out- side expertise and, if necessary, when to recall a product. SOPs can be an effec- tive tool that helps companies find an appropriate balance between encour- aging employees to respond decisively to GMP-related adverse events while preventing individual operators from making more generalized changes to a process without supervisory approval and revised documentation. Although the FDA has not defined specific criteria for achieving a state of "good manufacturing practice" for food packaging beyond the general safety requirement, one can infer that standard industry practice is sufficient when standard industry practice protects the health and safety of the consumer. Heroic measures are not required, but corporate culture and consumer expec- tations can effectively influence com- panies to exceed minimum standards. Technical limitations may serve as a justifiable limit on the scope of GMP; economic considerations, however, are certainly less defensible. When evaluating good manufactur- ing practice in a facility, manufacturers of food-contact materials should con- sider: (1) the present state of the industry at large; (2) the availability of current and emerging technologies; and (3) the degree of risk inherent to the consumer's intended or reasonably foreseeable use of the product. It follows that meeting the minimum requirements for GMP in 2018 may not be sufficient for achieving that same goal 10 to 20 years from now. Therefore, companies should continu- ally strive to offer maximum value and quality, while simultaneously endeavor- ing toward continuous improvement. Da iel C. Rube stei s a ssociate at Keller a d Heckma LP based i ash- i gto , D.C., a d is a member of the firm's food a d drug practice group. Rube stei assists compa ies, orga izatio s a d trade associatio s i stablishi g complia ce with regulatory requireme ts for food packagi g materials a d food i gredie ts throughout the U ited States, Europea io , Asia a d South America. Leveragi g his tech ical backgrou d a d expertise as a dustrial e - gi eer, Rube stei as experie ce i rocess optimizatio , i ve tory co trol, facility layout a d good ma ufacturi g practice i DA-reg- ulated facilities. Rube stei ses this experi- e ce to help clie ts develop quality co trol a d i ter al auditi g strategies, sta dard operati g procedures a d rapid-respo se pla s. Other resources The Food and Drug Administration has a number of publicly available resources for help with food safety, recalls and manufacturing practices. In addition to the websites below, Keller and Heckman LLP provide a comprehensive online resource at www.packaginglaw.com: • FDA's webpage for identifying and monitoring recalls: www.fda.gov/safety/recalls/ • Common foodborne illnesses and contaminants: www.fda.gov/Food/FoodborneIllnessContaminants/default.htm • General information on food packaging: www.fda.gov/Food/IngredientsPackagingLabeling/PackagingFCS/default.htm • The food-contact notification (FCN) program has a publicly available, searchable inventory: www.accessdata.fda.gov/scripts/ fdcc/?set=fcn • FDA's Office of Food Additive Safety also posts helpful information that assists companies in evaluating the safety of food-contact substances, including in the context of FCN submissions: – Chemistry guidance: www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ IngredientsAdditivesGRASPackaging/ucm081818.htm – Toxicology guidance: www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ucm081825.htm

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