Bought on Price, Stored Next to the Detergent: Why Kenyan Food Factories Should Treat Packaging Like an Ingredient

By Isaac Muthui, CEO, Tamalaki Business Network Ltd. Originally published at factoraerp.com.

Most food factories treat packaging as a purchasing item. It arrives on a lorry, gets counted, goes into a corner of the store and comes out when the line needs it. Ingredients get a specification, a supplier approval and an intake check. The pouch, bottle, tub or film that touches the food often gets a delivery note and a count.

Yet the packaging is the last thing between the product and the customer. A roll of film stored next to the pesticide cupboard, a carton of preforms left open under a leaking roof, or a batch of tubs from a new supplier that smells of solvent can undo everything the process did right. And when something goes wrong, the first question is "which packaging lot was on that batch?", which most plants cannot answer quickly.

This packaging material control checklist is written for dairies, millers, bakeries, juice, water, snack, edible oil and other Kenyan and East African food and agro factories. It does not replace your HACCP team, your certification body, KEBS, your county public health officer or your packaging supplier's technical advice. It sets out ten practical checks for treating food-contact packaging as what it is: a food safety material.

What the standards actually say

Codex. The Codex General Principles of Food Hygiene, CXC 1-1969, has a section on packaging. It says "packaging design and materials should be safe and suitable for food use, provide adequate protection for products to minimize contamination, prevent damage, and accommodate proper labelling". Packaging materials or gases "should not contain toxic contaminants, and not pose a threat to the safety and suitability of food under the specified conditions of storage and use", and "any reusable packaging should be suitably durable, easy to clean and, where necessary, to disinfect" (13.2.9). Codex also asks for "adequate and, where necessary, separate facilities for the safe and hygienic storage of food products, food ingredients, food packaging materials and non-food chemicals" (9.2.7), lists the food packaging material used as part of the product description for HACCP, and says flow diagrams should show where packaging materials enter the process.

The East African code. EAS 39:2001, the East African code of practice for hygiene in the food and drink manufacturing industry, says "packaging material used in contact with food, shall be free of contamination, shall not taint the food and shall comply with the relevant East African Standard Packaging Code" (4.3.10). Where glass containers are used for packaging, "the manufacturer shall establish suitable handling procedures, to eliminate the possible contamination of the food by glass fragments or splinters" (4.4.3). Insecticides and rodenticides must be used so as "to prevent the contamination of food or packing materials", and those "in similar containers to those used for packaging, shall not be used" (7.3.9). Stacking must be limited so that crushing does not damage "the product or packaging" (8.2.2.6). And one rule that is broken in many plants: "Packaging material, whether damaged or not, shall not be used as a waste receptacle" (10.8.4).

Kenya's food hygiene regulations. The Food, Drugs and Chemical Substances (Food Hygiene) Regulations made under Cap. 254 require the person in charge of a food plant to ensure that "packaging processes and materials are such as not to transmit contaminants to the products and provide adequate protection from contamination" (regulation 14(f)). They also require that pesticides are used so as to prevent "the contamination of food or packaging material" (regulation 12(g)), and that each container is "embossed or otherwise permanently marked in code or in clear to identify the producing factory and the lot" (regulation 14(d)).

Useful benchmarks. Neither of these is binding in Kenya, but both are useful for exporters and for writing specifications. The US rule 21 CFR 117.80 requires "appropriate quality control operations" to ensure "that food-packaging materials are safe and suitable", and that filling, assembling and packaging are done so the food is protected against allergen cross-contact, contamination and growth of undesirable microorganisms. The EU framework regulation on food contact materials, Regulation (EC) No 1935/2004, says materials must not transfer their constituents to food in quantities that could endanger human health, change the composition of the food unacceptably or spoil its taste and smell (Article 3). Its Article 17 requires businesses to be able to identify who supplied their food contact materials and to whom they went.

Why packaging control goes wrong

Packaging rarely fails because a factory ignores it. It fails because packaging sits between departments. Procurement buys it on price and lead time. Stores count it. Production uses it. QA looks at it only when a customer complains.

The patterns are familiar. There is no written specification, so a cheaper supplier's film is "the same" until it fails at sealing or smells of ink. Nobody asks the supplier for evidence that the material is suitable for food contact, or for this food at this temperature. Packaging is received without an intake check and stored on the floor next to chemicals or under a dusty mezzanine. Outer cartons go straight onto the line. Opened rolls and bags of preforms sit uncovered over the weekend. Empty pouches are used as bins for offcuts. And the batch record lists the product and the date, but not the packaging lot, so a supplier recall of a film becomes a guess about which production days to check.

The 10-step packaging material control checklist

1. List every packaging material and know which ones touch food

Make a register of every packaging item: pouches, films, bottles, preforms, caps, tubs, lids, liners, sacks, cartons, trays, labels and tapes. Mark each one as primary (in direct contact with food), secondary or transit packaging.
For each item record the supplier, the material, the products it is used on and where it is stored.
Primary packaging gets the same level of control as an ingredient. Secondary and transit packaging still matter, because they protect the product and carry the codes, but the risk is different.

2. Write a specification for each primary packaging item

The specification should state the material and construction, dimensions and tolerances, colour and print, how it is packed and labelled by the supplier, and what it will be used for: the food, the fill temperature, the storage conditions and the shelf-life. Codex asks that packaging be safe and suitable "under the specified conditions of storage and use"; those conditions should be on the specification.
Include what matters on your line: seal strength or seal temperature range, neck finish for bottles and caps, odour, and print on the outside surface only where that is the design.
Version the specification. When the supplier, material or design changes, the specification changes and QA approves it before the first delivery.

3. Ask the supplier for evidence, and approve the supplier

Ask each primary packaging supplier for a written statement that the material is suitable for contact with your type of food under your conditions of use, plus any test reports they hold. Ask KEBS or your certification body which East African or Kenyan standard applies to your material, since EAS 39 points to "the relevant East African Standard Packaging Code".
Approve packaging suppliers the same way as ingredient suppliers: questionnaire, documents, and where the risk justifies it, a visit. Our supplier intake checklist covers the process.
Ask the supplier to put a lot or batch number on every delivery and every carton or roll. Without it, step 7 is impossible.

4. Check every delivery before it goes into the store

Inspect the vehicle and the load: clean, dry, no pests, no strong odours, no chemicals carried with the packaging. Kenyan regulations already ask for containers and carriers of raw ingredients to be inspected on delivery; apply the same discipline to packaging.
Check the outer packaging is intact, the item matches the specification and purchase order, and the supplier's lot number is on the label. Take a small sample and check dimensions, print, odour and, for films, a quick seal test on the line or bench.
Record the supplier, the supplier's lot, the quantity, the date and the result. Reject or hold anything damaged, wet, unlabelled or out of specification. Put doubtful lots on QA hold until a decision is made.

5. Store packaging like food, away from chemicals and pests

Store packaging in a clean, dry, covered area that is rodent, insect and bird proofed, off the floor on pallets or racks, with space around the walls for cleaning and inspection, as EAS 39 asks for stores (8.2.2.4 and 8.2.2.5).
Keep it separate from cleaning chemicals, lubricants, fuels and pesticides. Codex asks for separate storage facilities for food packaging materials and non-food chemicals, and both EAS 39 and the Kenyan regulations require pesticides to be used so they do not contaminate packaging. Our chemical control checklist and pest control checklist cover the other side.
Limit stacking height so lower layers are not crushed, and use packaging in first-in, first-out order so old stock does not sit for months collecting dust.

6. Protect packaging on its way to the line

Remove outer cartons, shrink wrap and pallets in a de-boxing or transfer area, not on the production floor. Outer packaging has been on lorries and warehouse floors.
Bring to the line only what the shift needs. Keep opened rolls, bags of preforms and stacks of tubs covered, and close them at the end of the shift. Return part-used stock to the store wrapped and labelled with its lot.
Never use packaging as a bin, a scoop or a container for anything else. EAS 39 says packaging "whether damaged or not, shall not be used as a waste receptacle". Never put chemicals into anything that looks like your packaging.

7. Record which packaging lot went onto which batch

When packaging is issued to the line, record the supplier lot against the production batch, the same way you record ingredient lots. A line clearance check is a good moment to confirm it, as in our line clearance checklist.
Make sure every finished pack carries the code that identifies your factory and the lot, as the Kenyan regulations require, and that the code on the packaging matches the batch record. Our label control checklist covers printed information.
The test: if your film supplier tells you one lot of film is faulty, can you list every batch it went on, and where those batches were sent? Include packaging in your mock recall.

8. Handle glass and rigid containers with a written procedure

If you pack in glass, EAS 39 requires handling procedures to eliminate contamination by glass fragments. Write down how bottles and jars are received, stored, de-palletised, inspected, cleaned or air-rinsed and inverted before filling, and what happens when a container breaks on the line.
For a breakage: stop the line, quarantine product from the affected area, clean up under QA control, inspect and record before restarting. Our foreign body control checklist covers the glass register and breakage procedure in detail.
Apply the same thinking to rigid plastic: check preforms, bottles and caps for chips, flash and loose fragments at intake and on the line.

9. Clean, inspect and retire reusable packaging

Crates, milk cans, returnable bottles, bulk bins and reusable sacks must be "suitably durable, easy to clean and, where necessary, to disinfect", as Codex says. Define how each is cleaned, how cleaning is checked and who checks it. Our cleaning and sanitation checklist sets out the routine.
Inspect returnable containers before reuse. Reject any that are cracked, dented, stained, smell of something other than the product, or show signs they were used to store fuel, chemicals or pesticides. Those should never come back into food use.
Keep a count of reusable containers in circulation and remove damaged ones from service, so they are not quietly put back on the line.

10. Reconcile, segregate and review

At the end of each run, reconcile packaging: issued, used, wasted and returned. A gap tells you about waste, miscounts or packaging that went somewhere it should not. Our stock count reconciliation checklist explains how.
Keep non-conforming packaging (damaged, out of specification, obsolete design) clearly labelled and segregated until it is returned or destroyed, so it cannot be issued by mistake.
Review packaging performance monthly: intake rejections, line failures such as poor seals or leaking caps, and customer complaints that point to packaging. Raise them with the supplier in writing, and include packaging in your internal audits.

The packaging control record

For any primary packaging item, QA should be able to answer these questions from the records alone:

Question	What the record should show
What is it, and what is it for?	Specification reference and version, food and conditions of use
Is it suitable for food contact?	Supplier's food-contact statement and test reports, date received
Who supplied it, and is the supplier approved?	Supplier name, approval status and date
Was this delivery checked?	Intake record: supplier lot, quantity, date, checks done, result, initials
Where is it stored?	Location, separated from chemicals, off the floor
Which batches was it used on?	Production batch records carrying the packaging lot
What went wrong, and what was done?	Rejections, line failures, complaints and supplier responses

An illustration

This is an illustrative example, not a real case. A juice plant switches to a new supplier of PET bottles because the price is better. Nobody writes a specification, and the first delivery goes straight into the store next to the cleaning chemicals. Two weeks later a retailer reports an off-taste. QA suspects the bottles, but the batch records list only the product and date, and the bottles from the old and new suppliers have been mixed on the line. The plant has to hold three weeks of production. With a specification, a food-contact statement from the new supplier, an intake check that included odour, separate storage and the bottle lot recorded on each batch, QA could have confirmed or ruled out the bottles within an hour and held only the affected batches.

How FactoraERP helps

FactoraERP keeps purchasing, stock, production batches and quality checks in one system. That means packaging can be received, checked and issued through the same records as ingredients, instead of a separate notebook in the packaging store, and when a question comes up about a batch, the packaging used on it is part of the same history. See factoraerp.com.

Free download: eTIMS readiness checklist for factories

Kenyan manufacturers increasingly need their purchase records, stock records and invoices to tell one consistent story, and packaging is often one of a factory's largest purchases. If you want a free eTIMS readiness checklist for factories, sign up for the FactoraERP Insights newsletter at https://isaacmuthui.substack.com. You will get practical operations notes for food and agro manufacturers. No spam; unsubscribe anytime. For background, see our guide to eTIMS for food and agro manufacturers.

FAQ

What is packaging material control in a food factory?
It is the set of checks that makes sure packaging, especially packaging in direct contact with food, is safe and suitable: a specification, an approved supplier with evidence of food-contact suitability, an intake check, hygienic storage away from chemicals and pests, protection on the way to the line, and a record of which packaging lot was used on which batch.

What does Kenyan law say about food packaging?
The Food Hygiene Regulations under Cap. 254 require that packaging processes and materials do not transmit contaminants to the products and provide adequate protection from contamination, that pesticides are used so they do not contaminate packaging material, and that containers are marked to identify the producing factory and the lot. EAS 39 adds that food-contact packaging must be free of contamination, must not taint the food and must comply with the relevant East African packaging standard.

Should packaging be stored separately from chemicals?
Yes. Codex asks for separate storage facilities for food packaging materials and non-food chemicals such as cleaning materials, lubricants and fuels, and both EAS 39 and the Kenyan regulations require pesticides to be used so they do not contaminate packaging.

What should we ask a packaging supplier for?
A specification you agree together, a written statement that the material is suitable for contact with your food under your conditions of use, any test reports they hold, and a lot number on every delivery and every carton or roll.

Why record packaging lots on the batch record?
If a packaging supplier reports a problem with one lot, or a complaint points to the packaging, you need to know exactly which batches it went on. Without the packaging lot on the batch record, you have to hold or check everything produced in that period.

Can reusable crates and returnable bottles be used for food?
Yes, if they are durable, easy to clean and, where necessary, disinfected, as Codex says, and if they are inspected before reuse. Containers that are damaged, or that show signs of having held chemicals or fuel, should be taken out of food use.

Isaac Muthui, CEO, Tamalaki Business Network Ltd