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!