Sorry, it was a rather large off-topic. My only defence is that I had given up waiting for anybody to answer Simon's original very interesting question. I seem to remember that the model packaging HACCP plan presented on this site ended up with zero CCPs. Neat.
I sense your frustration that the original question has been dodged Charles, I would like to draw a parallel with the frustration felt by those in the packaging industry charged with ensuring product safety through Hazard Analysis and associated methodology. The fact is that whether you use HACCP, decision trees or risk based scoring it is very difficult and in many cases impossible to identify CCP's (as defined in Codex) within the packaging production environment.
Based on some unpleasant experiences, I usually select the 'receiving raw material of direct food contact, plastic packaging' as a CCP. This guarantees a discussion with the auditor. Can be literature validated if you search long enough.
That is very interesting, what kind of hazards do you associate with this packaging ?
Actually as you probably know detailed usable data on food safety incidents is also rare but its collation has certainly been promoted by HACCP. I deduce that data is even more scarce on packaging. I hope this is a comment that very few health incidents are statistically attributed to packaging defects ?
I wouldn't pretend to know the instances of incidents attributed to packaging defects, the data I had in mind was that comparable to pathogen levels in food where one can take the prevailing scientific advice as a basis for setting your critical limits. Although EU law places limits of certain substances in packaging material the level of these substances tends to be constant in a given material and unlike pathogens the levels are not altered by subsequent processes such as cooking. The fact that most packaging materials have no potential to promote the growth of pathogens removes a major hazard source and is one of the things that stumps the ex foodie embarking on a hazard analysis study of a packaging process.
Its been a few years since packaging customers started asking for HACCP and the BRC/IOP standard arrived but IMO the methodology for identifying CCP's in a packaging environment is still far from fully established, there is no Codex Packagingus Commision and very little guidance out there. Type 'HACCP for Food packaging' into Google and the only worthwile return is Saferpak.Com
I hope Simon won't think Im being presumptious but that lack of a definitive way to manage Hazards in packaging production is one of the main reasons for the existance of this site .
If it was easy to identify CCP's in the packaging environment then we would do so, the reliance on prerequisites may seem like a cop out but as this thread shows we strive to find the best way to identify and rate hazards so it's not through a lack of effort in the industry, rather its the nature of the beast.
Right thats the drum banged for the packaging boys and girls, Im off to the pub