Producers placing packaging, batteries and products on the market in France need to be aware that whilst the Green Dot logo has lost its mandatory status, the Triman Logo hasn’t.
The Triman logo is a mandatory, unified signage for end-of-life products created from the French Decree No.2014-15733 in order to harmonise the separate collection systems within France. This symbol was introduced to provide a more readily understandable symbol for citizens and consumers in France to ensure recyclable products are separated at end of life. In other words, if the product displays the Triman logo, the product should be recycled appropriately.
There are many Producer Compliance Schemes (PCSs) and collection organisations in France for different waste streams and over time they have developed their own communication methods, including different marking systems to inform consumers and guide waste sorting. In an effort to reduce any confusion, the Triman logo was introduced to specify separate collection possibilities to consumers, whilst also highlighting the recycling efforts of product vendors.
This Triman logo is not to be confused with the Green Dot logo (pictured left), which demonstrates compliance with local packaging legislation.
What are the Triman requirements?
The mandatory marking is required on all recyclable products under the Extended Producer Responsibility (ERP) umbrella which are placed on the French market. This includes the following products:
- Furniture and furnishings
- Graphic papers
- Clothing textiles
- Household linens
- Household packaging
- Electrical and electronic equipment
- Batteries and accumulators
- Products that generate specific non-point waste
Household glass packaging and products for professional use are excluded, as well as products that exhibit the crossed-out wheeled bin symbol. As it may not always be feasible for all relevant products to display the Triman logo, the marking must instead be displayed on the packaging, use instructions, the product website or any other medium that accompanied the product.
A useful handbook which contains this information, including the graphic appearance requirements, is available in English for all UK producers distance selling into France.
Complications despite good intentions
There are some complications with the existence of the Triman logo, despite its good intentions.
The Triman logo was brought in to harmonise the communication between consumers and the different collection systems, but this has not been harmonised on a European level. The Triman logo hasn’t been enforced in any other European country which means the compatibility with global trade is questionable. In a statement from 2013, before the Triman was introduced, the Industry Association wrote that they “strongly believe that the Triman measure fragments the internal market, is a barrier to trade, is more strict than necessary and is not proportionate to meet the objective being pursued”.
A report was published in April 2005 by the Federal Union of Consumers (UFC) titled Que Choisir which investigated the effectiveness of the Triman Logo four months after implementation. Their research showed that out of the obligated products tested only 20% were Triman compliant. With online shopping continuously increasing in popularity, the UFC suggested that the websites selling these products may have been displaying the Triman logo online instead, as this is in accordance with the Decree (no. 2014-1577).
Unfortunately during another survey it was revealed that 64% of products, including those from large international companies, were failing to display the symbol anywhere. The survey also showed that 81% of producers use multiple logos and that the Triman logo was often incorrectly used on items that were made up of multiple material types, leading to consumer confusion.
One of the many symbols that are likely to be seen on obligated items is the Universal Recycling Symbol (seen left) that is, along with its variants, recognised all over the world. The symbol holds a very similar meaning to the Triman logo – the object this symbol is placed on is capable of being recycled – so it’s not clear why the Triman logo is also required as it is effectively duplicating the Universal Recycling Symbol.
Above all, the Triman is expensive for obligated producers to implement – having to change the design of products and packaging to meet the requirements of only one national market – and is potentially contradicting its aim of simplifying waste sorting activities. There is also a lack of enforcement on record for any non-compliance, so now that the Green Dot is voluntary, maybe the Triman’s mandatory status could also be reviewed?
ISO 22000 revision
Revision is ongoing for ISO 22000 on food safety management systems, which has just reached the Draft International Standard (DIS) stage. The revised standard will incorporate a new core structure as well as recognized key elements to ensure food safety at every step of the food chain.
The ISO 22000 revision aims to consolidate the most recent issues surrounding food safety to suit the current landscape of the food sector. It is a very comprehensive process and the working group revising the standard has covered several extensive concepts. The experts met three times in 2016 and processed 1 800 comments from a variety of global stakeholders representing a broad range of positions. Now, their main task is to translate the revised concepts included in the standard and communicate these to the users in a clear and concise manner that makes ISO 22000 easier to understand and implement for organizations of all sizes, in every aspect of the food chain.
The new version of ISO 22000 will contain a number of minor alterations that have been introduced to increase the readability and clarity of the standard, as well as some substantial changes that are more structural in nature. The main highlights are as follows:
- The new version will adopt ISO’s new High-Level Structure (HLS), which is the common framework for all management systems standards. This common structure makes it easier for businesses to integrate more than one management system into their processes at a given time.
- The revised standard will provide a new understanding of the notion of “risk”. Risk is a vital concept for food businesses and the standard will distinguish between risk at the operational level (through the Hazard Analysis Critical Control Point approach, or HACCP) and risk at the strategic level of the management system (business risk) with its ability to embrace opportunities in order to reach a business’s specific goals.
- The standard will clarify the distinction between two Plan-Do-Check-Act (PDCA) cycles. The first applies to the management system as a whole while the second, embedded within it, addresses the operations described in Clause 8, which simultaneously covers the principles of HACCP defined by the Codex Alimentarius.
The revised version of ISO 22000 is expected to be published by June 2018.
Why revise ISO 22000:2005?
Since the first publication of ISO 22000 in 2005, users along the supply chain have been facing new food safety challenges – spurring a need for the standard to be revised.
It is normal process for an ISO standard to be revised. In fact, every 5 years standards are reviewed to determine whether a revision is necessary, to ensure that the standards remain as relevant and useful to businesses as possible.
Timeline of the revision
Currently the standard is at the committee draft stage (CD). This means that a draft revised standard will be available to ISO members for a vote in the first quarter of 2017.
More information on this process can be seen in the timeline below. Learn more about the process of standard development.
What are the main changes to the standard?
The major proposed changes to the standard include modifications to its structure as well as clarifying key concepts such as:
The high level structure: in order to make life easier for businesses using more than one management system standard, the new version of ISO 22000 will follow the same structure as all the other ISO management system standards, the High Level Structure (HLS).
The risk approach: the standard now includes a different approach to understanding risk.
The PDCA cycle: the standard clarifies the Plan-Do-Check-Act cycle, by having two separate cycles in the standard working together: one covering the management system and the other, covering the principles of HACCP.
The operation process: a clear description is given of the differences between key terms such as: Critical Control Points (CCPs), Operational Prerequisite Programmes (OPRPs) and Prerequisite Programmes (PRPs).
The Food Safety Modernization Act will soon have a dramatic impact on the food safety and regulatory landscape for facilities producing products regulated by the FDA. The Preventive Controls for Human Foods proposed rule, which is expected to be published as a final rule this month, will significantly change the way food manufacturing companies document their food safety systems. The traditional approach of using the HACCP (Hazard Analysis Critical Control Point) system will transition to the new HARPC (Hazard Analysis Risk-Based Preventive Controls) system. The change will be required by the new FDA regulatory standard defined in 21 CFR 117.26(a).
Food Safety Plan Requirements
FDA regulated facilities will be required to have a written and implemented Food Safety Plan. The Food Safety Plan must include the following contents:
The Food Safety Plan requirements are much more comprehensive than the traditional HACCP plan by itself. A HARPC hazard analysis includes more detailed hazard identification and hazard evaluation
Under HARPC preventive controls encompass numerous prerequisite programs including:
- Process controls
- Supplier controls
- Recall plan
- Hygiene training
- AND MORE!
Supplier and recall programs will become formal. Additionally, environmental monitoring as well as corrective and verification procedures will apply not only to critical control points (CCP’s), but to other preventive controls identified and documented by each plant.
As you prepare for the journey to transition from HACCP to HARPC, there are key steps on the way to become prepared and compliant. Focus on the following steps to help you understand and be successful:
Step 1 – Education and Training
The first stop is to take time to educate yourself on the new regulatory requirements and this new approach to your food safety system. The new regulations actually require food safety plans to be developed and reassessed by a “Qualified Individual.”
The proposed rule states a qualified individual must have successfully completed training in the development and application of risk-based preventive controls. Training must be equivalent to a standardized curriculum recognized as adequate by FDA.
It is recommended to attend an accredited HARPC training workshop such as the one offered by Alchemy or others to meet this criteria. The proposed rule does also state that job experience may be used to meet the criteria of a “qualified individual” if such experience includes developing and applying a food safety system, and knowledge at least equivalent to that provided through the standardized curriculum.
There is so much to learn about the regulations and this different approach to food safety that participation in a comprehensive training workshop is highly recommended.
Step 2 – Hazard Analysis
The hazard analysis identified in the 21 CFR 117.130 requirement looks substantially different than the hazard analysis under traditional HACCP Plans. The Hazard analysis is a two-step process: hazard identification and hazard evaluation. The primary differences identified in the proposed rule fall under hazard evaluation.
Hazard evaluation must include an assessment of the potential severity of injury or illness, and the probability that the hazard will occur in the absence of controls. This will require a quantitative risk assessment approach for all hazards identified.
- Radiological hazards must be considered
- Hazards that may be unintentionally introduced must be considered
- Hazards that may be intentionally introduced for purposes of economic gain must be considered
The hazard evaluation phase must also consider the effect of the entire manufacturing process including raw materials, formulation, storage and distribution and sanitation. Even extrinsic factors such as transportation practices and intended or reasonably foreseeable use must be included during this evaluation phase. This approach will require reassessments of existing hazard analysis, and changes the format of documentation. All the required information must be recorded.
Step 3 – Preventive Controls
Preventive controls are applicable to both CCP controls, and many programs often considered to be prerequisite programs. Preventive controls include process controls that are often associated with CCP’s such as cooking, chilling, temperature controls, pH control, and water activity (Aw) control.
Process controls must identify key control parameters including maximum or minimum values (i.e. critical limits or control limits) to be able to assess if the process is in control or not. Process controls specific to a manufacturer’s products, raw materials, processes and environmental factors must also be considered.
At a minimum, documentation of preventive controls required by the proposed rule include:
- Supplier controls
- Recall plan
Step 4 – Reanalysis
The Food Safety Plan will be required to be reassessed at the following times:
- Once every three years
- Whenever a significant change is made in activities conducted at the facility
- Whenever plants become aware of new information about potential hazards associated with the food
- After an unanticipated food safety problem occurs
- Whenever a preventive control is found to be ineffective
- Whenever FDA determines it is necessary to respond to new hazards and developments
It will be imperative to document a Food Safety Plan that meets the regulatory requirements and to reassess the plan as often as necessary based on the events above. The food safety plan should always be a living document that accurately represents your processes and controls.