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BRC/IOP clause 2.2.5


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#1 qualitymanager

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Posted 19 January 2017 - 02:42 PM

Hello everyone,

 

I m preparing the risk analysis for my company ( metal ends and cans)

 

i don't know what to do in the clause 2.2.5.

 

Does someoens has an idea or an example to send to me please?

 

 

thank you so much for your help


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#2 Tony-C

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Posted 20 January 2017 - 03:15 AM

The requirements for the this clause are quite detailed:

The hazard and risk analysis team shall identify and record all potential hazards that are reasonably expected to occur at each step in relation to the product and process. The hazards considered shall include, where relevant:

• microbiological

• foreign objects

• chemical contamination (e.g. taint, odour, allergen, component transfer from inks, varnishes and glues)

• potential problems arising from the use of recycled materials

• legality

• defects critical to consumer safety

• hazards that may have an impact on the functional integrity and performance of the final product in use

• potential for unintended migration of substances from the packaging material into food or other hygiene-sensitive product

• potential for malicious intervention.
 

Kind regards,

 

Tony


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#3 Foodworker

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Posted 23 January 2017 - 05:42 PM

It may help to give a few examples of potential hazards.

 

eg

 

Microbiological - If you are making normal can ends rather than speciality cans, there may be no microbiological hazards for your ends as the can will be heat processed by your customer.

Foreign objects - Most normal physical contamination such as  dirt/debris from the environmenrt but also slivers from the press and trimming stages.

Chemical - Lubricants, cleaning materials, undercured compounds, laquers and inks

Recycled Materials - Although there is probably a relatively large proprtion of recycled metal used I assume they will be subject to high temperatures in the recyclinh process which would remove any organics such as residual inks and mineral oils so ther will probably be no hazards relevant.

Legality - Can vary according to where you sell them so also look at your export market. BPA in France is an example if you are not using BPA free laquers. 

Defects Critical to Consumer Safety - Pinholes, damage/defect around easy open tags.

Functional Integrity - Could be size and shape to permit correct overlap. Missing compound. I would look at mixed print designs under this heading

Migration - incorrect or undercured laquer. Migration of materials from printed surface to food contact surface when packed in sleeves.Several years ago there were instances of taint from pentachlorophenol from layer pads and kraft paper sleeves.

Malicious Intervention - Could be your staff or within the supply chain.

 

There will be others and some may be specific only to your operation and equipment.

 

Be systematic, go through each process step and brainstorm potential hazards from each of the stated categories. Record them all but If there are none identified say so, Your next step will be to look at the likelihood and severity and probably most of the hazards you have identified will not translate into high risk points

 


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#4 Tony-C

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Posted 23 January 2017 - 06:25 PM

Thank you Foodworker, some great examples of hazards provided.

 

I am wondering whether BPA is a legal hazard or a chemical hazard or both and not just in France?

 

Also in defects if the can is not to specification could that be a hazard?

 

Kind regards,

 

Tony


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#5 Foodworker

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Posted 23 January 2017 - 08:48 PM

Inevitably a bit of both.

 

BPA is not illegal in the UK for instance, providing it is below the limit in the epoxy regs, but it is completely illegal in France and a couple of other countries.

 

The specification element can be a hazard such as the example of size I gave which will make a poor seal when the final can is made. Some cans ends are odd shapes as well (eg corned beef) which makes the specification issue much more important. 

 

I really must spellcheck my posts


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#6 Polin

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Posted 24 January 2017 - 07:55 AM

Hello everyone!

 

Thank you Foodwoker for the examples!!!

 

Could you mention some extra examples for flexible food packaging (printing and laminating films) ?  

I mainly interested in to the categories

  • Microbiological 
  • Legality

am wondering whether Allergen is a chemical contamination hazard (as stated in 2.2.5) or an independed hazard ? I stated Allergen as chemical hazard in our risk assesement but a systems consultant had an other opinion, that allergens are independed hazard. 

 

Thank you in advance 

 

Polin


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#7 Charles.C

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Posted 24 January 2017 - 09:52 AM

 

Hello everyone!

am wondering whether Allergen is a chemical contamination hazard (as stated in 2.2.5) or an independed hazard ? I stated Allergen as chemical hazard in our risk assesement but a systems consultant had an other opinion, that allergens are independed hazard.

Thank you in advance

Polin

Hi Polin,

 

BRC5 Packaging -

 

Allergen - A known component which causes physiological reactions due to an immunological response'

 

"Component" is ambiguous. "Causes" is ambiguous. "independent" sounds ambiguous also.

 

Based on above, I daresay you can both be right, possibly even simultaneously, depending on yr chosen interpretations, eg egg/albumen/ovomucoid

 

Note that BRC uses the word "includes" in 2.2.5

 

From a hazard analysis POV, IMO, you may include "allergens" within the hazard category  "Chemicals" or separate it as its own Category. IMEX nobody cares. Except seemingly yr SC. :smile:

 

PS - One wonders when BRC5 will include radiological hazards ?.


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Kind Regards,

 

Charles.C


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#8 Foodworker

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Posted 24 January 2017 - 02:23 PM

It is difficult without seeing your process and product types, but certainly two key hazards are going to be residual solvent and delamination.

 

Other hazards may depend more upon the products that you make. For instance if you sell products which claim to have a functional barrier to specific gases there may be potential hazards relating to the formation of the multilayers.

 

Looking specifically at microbiological hazards, there may be none, but again it may depend upon your products. Extruded films themselves will be essentially sterile because of the temperatures involved and will be unlikely to pick up bugs through the printing processes and lamination because of the solvents used(not true in every case). However if you take the printed reels and finish them into bags etc., there will be more manual handling and hence more potential for bugs.

 

For legality hazards there may be none and, as has been indicated in the various earlier posts, if there are any, they may equally and subjectively fall into the chemical or other categories. Look at the make up of your inks. I have often found ink suppliers not to be very helpful saying that inks are not included in the food contact regulations. This may be so at the moment but for EU10/2011 the whole finished product is included, plastics, inks and varnishes. Check the components of the inks and that they do not contain materials not approved under 10/2011. Again, cross check your export market. The Swiss for example have tighter rules. 

 

For allergens, I normally have a separate allergen risk assessment. This is not to comply with any particular Standard, but at some point one of your customers will ask you for your allergen policy and it is easier to send them a single set of documents rather than copy and paste from a larger Hazard and Risk analysis.


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#9 Polin

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Posted 25 January 2017 - 07:35 AM

It is difficult without seeing your process and product types, but certainly two key hazards are going to be residual solvent and delamination.

 

Other hazards may depend more upon the products that you make. For instance if you sell products which claim to have a functional barrier to specific gases there may be potential hazards relating to the formation of the multilayers.

 

Looking specifically at microbiological hazards, there may be none, but again it may depend upon your products. Extruded films themselves will be essentially sterile because of the temperatures involved and will be unlikely to pick up bugs through the printing processes and lamination because of the solvents used(not true in every case). However if you take the printed reels and finish them into bags etc., there will be more manual handling and hence more potential for bugs.

 

For legality hazards there may be none and, as has been indicated in the various earlier posts, if there are any, they may equally and subjectively fall into the chemical or other categories. Look at the make up of your inks. I have often found ink suppliers not to be very helpful saying that inks are not included in the food contact regulations. This may be so at the moment but for EU10/2011 the whole finished product is included, plastics, inks and varnishes. Check the components of the inks and that they do not contain materials not approved under 10/2011. Again, cross check your export market. The Swiss for example have tighter rules. 

 

For allergens, I normally have a separate allergen risk assessment. This is not to comply with any particular Standard, but at some point one of your customers will ask you for your allergen policy and it is easier to send them a single set of documents rather than copy and paste from a larger Hazard and Risk analysis.

 

Foodwoker thank you again,

 

our process: we receive extruded films in reels (polypropylene, polyethylene,polyester etc) and converting them into printed, laminated reels and/or bags.

 

Microbiological hazards: In our Risk Analysis state that due to the nature of the films there are no microbiological hazards, except from the hazard of cross contamination by the personell. The hazard is low because the personell is trained in GMP rules (PRP). I was wondering if we should consider the microbiological hazard in bug making as medium because of the handling manual

We apply periodically microbiological analysis in our final products. Is this an OPRP isn't? 

 

Regarding the funcional barrier and the formation of the multylayers, we do not take into consideration any hazard because we receive the films with oxygen and water barrier (only) only from approved suppliers with quality systems and with the appropriate certifications for the product. Should we nevertheless identify the hazard?

 

We identify the allergen hazard as potential by cross contamination. For the reduction of the risk, we training our personel and our cooperating company which provide automatic food sellers in our site.

 

Thank you in advance 

Polin


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