11 replies to this topic

[Malar]

Hi All,

 

In food packaging, what and how do we define CCP??

We have conducted HACCP analysis and training. However, my team and myself are uncertain on the CCP determination.

 

I am from Printed paper food packaging- High Risk category.

 

Appreciated if anyone can help me out here.

 

Thank you.

Hemala

[Charles.C]

Hi All,

 

In food packaging, what and how do we define CCP??

We have conducted HACCP analysis and training. However, my team and myself are uncertain on the CCP determination.

 

I am from Printed paper food packaging- High Risk category.

 

Appreciated if anyone can help me out here.

 

Thank you.

Hemala

 

Hi Hemala,

 

If this relates to BRC Packaging, the definition is in the glossary at the end.

 

Note the word "product".

 

It's a little old but Simon has posted a model Packaging haccp plan on this forum if of interest.

 

A website for haccp plans (for packaging) also exists which has been referenced here many times.

 

I don't quite understand how you have conducted a haccp training course without knowing what a CCP is ?

[Watanka]

Hemala,

 

First steps are to form a HACCP committee and get some training.  At a minimum your HACCP coordinator/committee chair should obtain certification in HACCP.  Classes can be taken online or in a classroom.  That training will guide your HACCP coordinator to help the committee to perform all the steps required to determine what, if any, critical control points are required.  There are no easy, off the shelf answers.  Each facility is different. The challenges you face will not be exactly the same as anyone else.  If need be you can hire a consultant to assist you in the development of your HACCP plan including the required training, but ultimately it is the HACCP committee who will make the determination of any CCP's.

 

Good luck!

[CMHeywood]

Codex Alimentarius decision tree is often used to determine if preventative control or CCP.  (see http://edis.ifas.ufl.edu/fs140)

 

I think some of the confusion about CCP's arises because people are using the term "Critical" to mean "Important".  All control measures for accept/reject decisions are important, otherwise you would not continue doing them (QA testing, visual checks, monitoring registration, etc.)

 

CCP:  the last step in the process where contamination is eliminated or reduced to an acceptable level.  There is a good chance of contamination being present.  An example is pasteurizing milk because raw milk likely will contain bacteria.  You are not able to demand and require bacteria-free milk from all your suppliers.

 

Prerequisite Programs (PRP's) - Preventative Controls:  procedures and policies that are required before accepting the raw material or before running the process.  A good example would be the requirement for your raw material suppliers to cover their products, use pallets that are not treated with pesticides, etc.

 

 

 

 

HACCP was developed for the food industries where contamination was routinely expected to be in the raw materials or in the manufacturing process.  For a food packaging converter, you may not have any CCP's since you would likely deal with the possible sources of contamination through PRP's and Preventative controls.

[Malar]

Hi CMHeywood,

 

You are right. It would have been easier if it is food processing. CCP could be easily determined ex: temperature, speed of pasteurization, cooling period and so on.

 

Our confusion is how to decide CCP in paper printing industry.

In our manufacturing process, paper sheeting, printing, die cut and gluing process we are uncertain on which or what could be a CCP/OPRP.

My team is not very well -versed in HACCP, even though we have been to HACCP training.

 

Last year during audit, we declared no CCP. We stated that GMP practices are in place to eliminate the contamination or cross contamination or any hazards to product. However, the auditor refuses to accept. She said we must have at least OPRPs.

 

So at the moment, my OPRPs are compressor air and glue quantity only.

Is this sufficient?? Or do I need to add few more??

Can I choose a parameter as CCP/OPRP if i could not verify and control it. ex: ink drying time.

 

Thanks.

[Charles.C]

Hi CMHeywood,

 

You are right. It would have been easier if it is food processing. CCP could be easily determined ex: temperature, speed of pasteurization, cooling period and so on.

 

Our confusion is how to decide CCP in paper printing industry.

In our manufacturing process, paper sheeting, printing, die cut and gluing process we are uncertain on which or what could be a CCP/OPRP.

My team is not very well -versed in HACCP, even though we have been to HACCP training.

 

Last year during audit, we declared no CCP. We stated that GMP practices are in place to eliminate the contamination or cross contamination or any hazards to product. However, the auditor refuses to accept. She said we must have at least OPRPs.

 

So at the moment, my OPRPs are compressor air and glue quantity only.

Is this sufficient?? Or do I need to add few more??

Can I choose a parameter as CCP/OPRP if i could not verify and control it. ex: ink drying time.

 

Thanks.

 

hi Malar,

 

Confusion definitely reigns supreme.

 

Maybe it relates to yr location but afaik, the terminology "OPRP" is a term invented for the iso/fssc22000 standards. Only.

 

I have not seen any mention of above 2 standards in this thread so far ??

 

BRC5 Packaging (sub-forum at top of page) Standard does not use the term OPRP.

 

So either yr auditor is talking nonsense, is at the wrong facility,  or something in this thread is well mixed up.

 

Perhaps you could clarify what is actually "going on".

 

For an intro. to (traditional) packaging haccp maybe see this website -

 

http://www.iopp.org/...cfm?pageid=2267

 

( I am not a packaging person but the tabular method shown looks quite good to me [based on that of food]. The decision tree is incomplete IMO, cf. the table)

(the initial definition for CCP is (obviously) for food. Maybe they will update it some day. Other defs. looked relevant)

 

The model haccp plan originally posted by Simon for a much earlier version of BRC packaging (ca,2003) is here -

 

http://www.ifsqn.com...kaging-company/

(inside the zip file)

[campbell]

It is not for the auditor to state that there must be CCPs or even OPRPs.  It is for the company to justify its HACCP plan.

I have audited both food & packaging for a number of years and depending on process and prerequisite programs in place there may or may not be any CCPs present.  If there are no CCPs then other controls MUST be validated and fully operational...

If the audit was from a certification body then suggest you take it up with the them.  The object of auditing tis to check for compliance with the standard.

[CMHeywood]

As mentioned above, BRC does not use the term "OPRP".  The company I work for has SQF certification.  SQF does not use the term "OPRP".

 

The point that I think some auditors and other entities, such as customers (not consumers), are not understanding is that HACCP is about identifying and controlling food safety hazards.  A packaging manufacturer may or may not have CCP's; it depends on whether there is a food safety hazard that can and must be controlled at a particular point in the production process. 

 

However, given the different terms that are found in different food safety schemes:

 

CCP - last point in the process where the food safety hazard can be controlled (eliminated or reduced to acceptable level).  It is the last point since you want to make sure it does not re-occur later in the process flow and you neglect to address it properly.  Example - it is assumed that pasteurization has eliminated or reduced the bacteria in the milk so it remains food safe throughout the rest of the process.  Further steps in the process must be kept clean and sanitized so bacteria is not re-introduced into the milk.  However, this is a focus on the process and not the product.

 

OPRP - prerequisite program that focuses on a particular process or operation, such as cleaning and sanitation procedures for a particular machine.

 

PRP - prerequisite program that has a general scope, such as pest control, personal hygiene, food safety training, etc.

 

See this website:  http://blog.etq.com/...rp-oprp-podcast

 

Regarding ink drying:  

What is the hazard - backside transfer of ink that would contact the food product?

What is the control measure - temperature and air speed of ovens or fans?

What is the critical limit - ink has dried to 90%?  Test how - visual check?

If not completely dry, is material scrapped at a later process such as slitting?  Would this be the last point where it is controlled?

[Charles.C]

Hi CMH,

 

IMO yr interpretation of an OPRP is obsolete. Better to refer to iso22004.

PRP is IMO nowadays best referred to iso22002 where iso is involved, mandatory or otherwise.

Yr def. of CCP is IMO logically incomplete, ie "essential". Some texts will also object to yr location interpretation however i agree that it matches the Codex Tree of 1997 et seq.

 

IMO the problem with OPRP rests with ISO. i sympathise somewhat with auditors.

[CMHeywood]

Charles, I must defer to your greater expertise.  I am relatively new to food safety (3 years) and I am still learning.

 

However, this does show in part the confusion, difference in opinions, and an apparent lack of standardization that many people face when they start addressing and implementing food safety.

 

As this discussion chain has shown, even auditors are sometimes making statements (like must have CCP and/or OPRP) that may not reflect the what is actually required or needed.

 

I think this is an example of the old Chinese blessing/curse:  "May you live in interesting times."

[Charles.C]

Hi CMH,

 

Sadly, i am also still learning particularly since i am originally a mere chemist.

 

I should add that i am highly anti-OPRP which may bias my opinions somewhat. I think the concept originally had benefit but ISO succeeded in making it totally unintelligible. And, as you say, the result  is a zillion and one versions floating around.

 

I also agree that Packaging is tricky where CCPs are concerned. The P. industry may well regret ever hearing the term HACCP.

 

I anticipate that the Chinese also invented cookies ?

[Simon]

In my experience outside of your standard prerequisite programs the most significant hazards in printed food packaging are mixing of printed designs; as potentially this could lead to incorrectly labelled product that could put the consumer at risk.  Imagine a hazelnut yoghurt that is labelled as strawberry and what that could do to a consumer with a nut allergy.  Some of the key controls for preventing mixed packaging would be good print controls such as plate media management as well as good systems of product identification, segregation and workplace organization to prevent inadvertent mixing and importantly robust line clearance between production orders including any rework operations.  You would expect line clearance to be recorded and verified by a second operator; these records would also be checked at the end of an order by a supervisor or manager.  If not completed correctly then you would withdraw the product for inspection and the corrective action may be to retrain operators. If you want to call it a CCP then go for it.  By the way where businesses do composite printing (side by side printing of different designs) then this can introduce more risk of mixing especially when the printed product is converted.

 

Along a similar theme if there is incorrectly printed ingredients or print defects on ingredients then again this could lead to issues for consumers (especially with allergens).  Again the controls in printing for assuring this would need to be robust.

 

Just a couple of areas to consider that can be HIGH RISK for printed packaging.

 

Regards,

Simon