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#1 scrumpyone

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Posted 25 November 2010 - 05:32 PM

:helpplease: We have just commenced our journey towards cat 2 packaging standard.:dunno:

The first hurdle we have come across is that whilst identifying the hazards in each process we're unsure whether to include eating & drinking on shop floor and risks from bacteria as eventually these will be covered off in the prerequisites.

Any guidance appreciated.

Thanks.

Dave
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#2 Tony-C

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Posted 26 November 2010 - 04:39 AM

:helpplease: We have just commenced our journey towards cat 2 packaging standard.:dunno:

The first hurdle we have come across is that whilst identifying the hazards in each process we're unsure whether to include eating & drinking on shop floor and risks from bacteria as eventually these will be covered off in the prerequisites.

Any guidance appreciated.

Thanks.

Dave


Hi Dave

You should establish your prerequisites before conducting a hazard analysis. This is so your HACCP plan is not over complicated. I am assuming that you have prerequisites like a Hygiene Policy in place so you should conduct the hazard analysis taking into account these control measures.

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Tony
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#3 Simon

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Posted 26 November 2010 - 08:48 AM

I agree with Tony. For example contamination from pest issues could in theory occurr at every or any step of the process. The prerequisite would be to have a comprehensive and effective pest contol system in operation. It's the same for cleaning, personal hygiene, blade control, glass control etc.

Like Tony said you get these developed and implemented and then you can look at the specific hazards relating to the process steps.


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#4 scrumpyone

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Posted 26 November 2010 - 09:34 AM

Thanks guys,

I sure am glad I joined this forum :clap:


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#5 Simon

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Posted 26 November 2010 - 09:50 AM

If you have any further questions just ask. :smile:


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#6 Foodworker

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Posted 29 November 2010 - 09:54 AM

Good Morning Scrumpyone.

I am attaching some extracts from a hazard analysis that I developed for a label printer which you may find of use. They passed their BRC/IoP (Cat 2) without too many problems.

Please remember that a hazard analysis is unique to each site and what may be unimportant in one could be critical in another. For instance, this plan was for a third world country and pests were a particular problem. Hence pest inspection of incoming materials was considered to be a CCP, whereas is 99% of operations pest control is part of the prequisite programme.

By the way, if you want any on site help, I can easily be persuaded to come to the Cayman Islans as it is freezing in the UK today!


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#7 Foodworker

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Posted 29 November 2010 - 01:10 PM

Here are the files.

Attached Files


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#8 scrumpyone

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Posted 29 November 2010 - 01:48 PM

Hi Foodworker,

This site is brilliant. Appreciate your efforts & look forward to the uploads.

BTW, I'm actually in the UK (my username is a bit of a clue whereabouts)!

But going to Grand Cayman this Saturday for a couple of weeks R&R.:notworking:


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#9 scrumpyone

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Posted 29 November 2010 - 01:51 PM

Hi Foodworker,

This site is brilliant. Appreciate your efforts & look forward to the uploads.

BTW, I'm actually in the UK (my username is a bit of a clue whereabouts)!

But going to Grand Cayman this Saturday for a couple of weeks R&R.:notworking:


Ah there they are. Thanks Foodworker.
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#10 Charles.C

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Posted 29 November 2010 - 07:33 PM

Dear foodworker,

Thks for the documents.

It’s an interesting system. I am not in packaging and so unfamiliar with the details of the BRC packaging standard. I appreciate that the application of (food based) haccp principles to packaging is inevitably not straightforward so no problem to be corrected if I hv misunderstood some items but yr “haccp” setup seems rather odd to me, eg -

(1) the haccp system seems rather defocused / cluttered due mixing BCP parameters with FI and legality. The first priority of haccp IMO is safety, I presume the FI parameter can refer to anything, ie safety or non-safety.? Maybe this additional parameter is stipulated by BRC?, (I am sure that legality is) but it still seems preferable to split the safety aspects off IMO. I did wonder if yr setup was modified from a FMEA procedure. :smile:

(2) I believe the intention of the hazard analysis is to accurately specify the hazard. It is true that, for example, denoting hazards as due to “pathogenic bacteria” is also quite common in food analyses but IMEX this often indicates ignorance of what the hazards actually are. I hv found that auditors are delighted to find such omissions, easy NC. In this respect yr critical hazard of “incorrect films, plates, die cuts etc” seems simply ambiguous, whether safety or non-safety.

(3) I do not think is it meaningful to present a hazard analysis without preventive measures. Surely that is the (proactive) intention of the analysis / determination of ccps ? Maybe there was a page missing ? (I deduced from yr post that the amazingly high expected occurrence of items like pest contaminated raw materials was related to the location, i only hope that a preventive measure was found !! :smile: )

My comments are hopefully constructive, appreciate yr offering the system for viewing.

Rgds / Charles.C


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#11 Foodworker

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Posted 30 November 2010 - 11:28 AM

Morning Charles,

The documents were only a few extracts from the hazard analysis study and there is a whole bunch of supporting info and SOPs linked to it.

The BRC packaging approach to hazard analysis is one of the few areas where I think they have got it right. One of my pet subjects is the difference between HACCP for food and hazard analysis for packaging.

In food, the hazards are, by and large. biological, physical and chemical. In packaging, yes these can occur, but the relative severity is low as the packaging is rarely consumed.

Foreign bodies will always occur but they will normally be controlled by PRPs. Bird swings in bottle/jar manufacture is probably the major exception to this rule.

Chemical contamination can take the form of accidental additions of cleaning chemicals, lubricants etc. There are inherent chemical problems such as migrations from polymers, residual solvents from printing and lamination, phthalates, ITX/methylbenzophenones and of course the current fashionable BPA. All of these are undesirable and toxic/carcinogenic but the amount you would have to consume to have any real harm is much more than is probable.

For microbiological risks, the packaging manufacturer has really got to do something apalling to have any significant problems. It does happen, a straw manufacturer I visited in the Far East once was cooling the extruded straws in a water bath which looked more like a septic tank!

Chemical, physical and micro hazards are included partly because the standard says so and partly because BRC/IoP auditors are commonly food auditors who like to see the bits that they are comfortable with.

So what are the hazards? The standard requires that you evaluate hazards related to Chemical, Physical and Biological plus " legality and defects critical to consumer safety as well as those which have an impact on the functional integrity and performance of the final product taking into account the customer requirements" - The wording may change in issue 4.

The functional integrity aspects are where most real packaging hazards occur. There are very few ways that packaging can kill a consumer but mixing of printed materials such as diabetic/non diabetic products is possibly one. The inability to read allergen or storage advice because of poor or missing print is possibly another. Hence the docs leaned heavily on the control of artwork and plates, line clearance etc. Other functional integrity hazards could be film delamination breaking down a gas barrier for MAP, wrongly applied lacquers or sealing compounds for cans or jars allowing the food to corrode the metal and of course there are loads more. This is why the Functional Integrity hazards can also be safety hazards.

There is no right or wrong way to do a packaging hazard analysis, the analytical tools of HACCP or FMEA can work equally well. Most packaging companies start off their journey to certification without any knowledge of hazard analysis and look for help with consultants or the internet and end up with a food HACCP system at their first attempt. This is because there is not a lot of decent help or training available. Simon's new course may help plug this gap.

Sorry its a bit long winded and I hope it makes sense!


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#12 Charles.C

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Posted 30 November 2010 - 01:28 PM

Dear foodworker,

Thks for detailed comments / clarifications. Very readable. :smile:

Must confess I had not realised how far the model haccp scheme which Simon posted here some time back is now out-of-date with respect to current brc packaging hazard analysis requirements, eg no mention of FI (as far as I can see).

I deduce that FI can refer to both safety / non-safety hazards. Should be clearly separated IMHO.
(Some buyers / standards, eg Woolworths Australia / SQF have done a similar backwards time travel with food haccp, albeit using a new terminology [I think]). (I’m sure you know all this already :smile: ).

I sincerely hope that the BRC / Packaging Standard doesn’t refer to this 5-6 element, concocted mix as their “haccp system.”

I have to maintain my preference for a format such as the Kraft draft layout below (+ some horiz. > vertical re-arranging + risk assessment columns) where a possible control mechanism and precise hazard are more fully detailed. I guess it’s due to coming from a food direction. Maybe packaging auditors are more, err, flexible.

Attached File  KraftPkgHACCP_KFExample.doc   606KB   146 downloads
(previously posted here by myself but original link now > 404 error)

Rgds / Charles.C


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#13 scrumpyone

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Posted 30 November 2010 - 02:08 PM

Charles,

This also looks very useful.

Thanks.


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#14 Foodworker

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Posted 30 November 2010 - 03:44 PM

Thanks for the Kraft download, I haven't seen that one before.

The study for my company had additional CCP pages and summaries with process flows, justifications, control mechanisms, verifications and validations etc., but I didn't post these as there were a couple of commercially sensitive points within them. They included all the line clearance procedures and a number of other SOPs.

The CCPs in the Kraft model were essentially line clearance and artwork approval, which were also some of the CCPs in my post.

These would be classified as Functional Integrity under my example. Kraft have classified them under 'chemical' and have linked them to allergen. There is nothing wrong with this but it is restrictive and it is almost as though they have identified a risk and they are looking for which of the 3 normal categories it fits best with. The same problems with mixed products and correct artwork/print could apply in non allergenic products. Examples are storage instructions, shelf life, dosage or dilution instructions. Although Kraft are looking at food, packaging obviously can be used in non foods or pharmaceuticals where different risks may apply but still need to be controlled.

I come from a food background and it took me a long time to get my head around packaging hazard analysis but I think I have nearly got there. I used to do a bit of packaging work with Heinz and it was they who brought it home to me. Their view at the time was that if a company presented them with a standard HACCP they wouldn't accept them as a supplier.

I know we are getting off scrumyone's original post but this is an enjoyable discussion!


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#15 Charles.C

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Posted 30 November 2010 - 06:27 PM

Dear Foodworker,

Yes, I take yr point regarding non-food applications.

I also hv no problem regarding simplifying the presentation of the hazard analysis as far as possible, provided that someone else can pick it up and make sense of the flow / content. It's a fact that other than via Excel, not easy to get all the HA segments on one sheet. If the FI grouping method still maintains clarity, good to go.

I guess the allergen emphasis is an inevitable response to its being (I think) the No.1 cause of retail food withdrawals / recalls in UK and probably elsewhere. Some of them are almost cartoon cases, eg (Australia)

•19th Feb: Kinnerton
- Spiderman 3 Chocolate Easter Egg (in ceramic mug)
- "Nut free" label, plus “may contain tree nuts, peanuts and seeds”


Not necessarily attributed to a packaging production error of course. :smile:

I’m still wondering how you solved the case of the pest-infected packaging. :biggrin:

Rgds / Charles.C
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#16 Foodworker

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Posted 30 November 2010 - 07:30 PM

Its good to keep some secrets!


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#17 scrumpyone

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Posted 01 December 2010 - 09:24 AM

:bug: :cm:
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#18 Charles Chew

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Posted 10 December 2010 - 03:36 AM

Enjoyed reading this one very much. :clap:


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#19 BBrandDesign

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Posted 02 May 2011 - 07:59 AM

Hazard Analysis & Critical Control Points (HACCP) is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product.


A hazard may be a biological, chemical, or physical property that can cause a food to be unsafe. The analysis of hazards requires the assessment of two factors with respect to any identified hazard, i.e., the likelihood that the hazard will occur and the severity if it does occur.


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#20 scrumpyone

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Posted 06 May 2011 - 10:49 AM

Hi all,

We've now completed our process flow, identified the hazards at each step, documented the control method & scored each one. This has left us with 4 CCP's. My question now is: do we need to come up with critical limits for all of the hazards in all processes or only those recognised as CCP's?

:dunno:

Thanks in anticipation.


Edited by scrumpyone, 06 May 2011 - 10:51 AM.

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#21 Foodworker

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Posted 15 May 2011 - 05:54 PM

This is always a debatable point.

For a Critical Control Point, limits will be by definition critical.

However, you are likely to have a number of other control points which you have determined not to be CCPs. Many of these will have a measurable tolerance which you will still need to work to. Failure to meet these limits may result in substandard, if not unsafe, product.

Define the limits, just don't call them critical.


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#22 Simon

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Posted 21 May 2011 - 06:34 PM

Hi all,

We've now completed our process flow, identified the hazards at each step, documented the control method & scored each one. This has left us with 4 CCP's. My question now is: do we need to come up with critical limits for all of the hazards in all processes or only those recognised as CCP's?

:dunno:

Thanks in anticipation.

Scrumpyone, as a matter of interest can you tell me what your 4 CCP's are?

Thanks,
Simon
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#23 Charles.C

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Posted 22 May 2011 - 03:11 PM

Dear scrumpyone,

Completely missed yr preceding post first time around.

I don’t wish to “muddy the waters”, particularly since my knowledge base is not in Packaging however I wonder if part of the answer to yr post is defined (somewhere) by the specific standard involved. (maybe Foodworker's opening line already implied my following paragraph, if so apologies in advance :dunno: )

“CCP” is AFAIK a specific terminology reserved for traditional haccp / some derived systems such as in ISO 22000.
But does the increased range of hazards introduced by BRC Packaging also require an expanded use of “CCP”, eg for categories such as legal, F1? (this would then be analogous to the original [but subsequently narrowed] usage of haccp which included aspects such as economic fraud, “quality” etc in addition to purely safety-oriented hazards).

If “CCP” usage remains safety-restricted, then I concur with Foodworker’s post in the general sense however whether you need to actually devise limits for a specific (presently unknown) hazard will presumably depend on the correctness of yr evaluation. And similarly for Simon’s enquiry.

Rgds / Charles.C


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#24 scrumpyone

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Posted 31 May 2011 - 08:11 AM

Thanks for responses guys.

We actually identified 3 CCP's (not 4) :doh:

They are: 1. Adhesive backing on label stock unsuitable for food application.
2. Ink used not suitable for food application.
3. Ink not sufficiently dried/cured & migrating from label.

Controls required for items 1 & 2 would be certificates of conformity from suppliers, along with inspection at goods inwards. For item 3 we have maintenance programme for ink drying units & rub test during production.

Simon, does it sound like I'm on the right track here?




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#25 Simon

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Posted 31 May 2011 - 06:34 PM

Thanks for responses guys.

We actually identified 3 CCP's (not 4) :doh:

They are: 1. Adhesive backing on label stock unsuitable for food application.
2. Ink used not suitable for food application.
3. Ink not sufficiently dried/cured & migrating from label.

Controls required for items 1 & 2 would be certificates of conformity from suppliers, along with inspection at goods inwards. For item 3 we have maintenance programme for ink drying units & rub test during production.

Simon, does it sound like I'm on the right track here?

Hi Scrumpyone,
I would say 1 and 2 are not CCP's, but 3 could well be.
You should focus contols, monitoring and corrective action on ink curing / drying. GMP / print process controls to prevent ink set off / ink transfer is law in EU and also version 4 of the BRC/IOP majors on this. One other thing to consider is your ink system low migrattion - ask your ink supplier? You may have to conduct regular end product migration testing to validate your controls.

By the way is your product direct food contact?

Oh and often in packaging mixed designs is a CCP with robust line clearance procedure being the key to prevention

Regards,
Simon
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