How about putting it through the BRC Packaging Version 5 criteria?
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:
- foreign objects
- chemical contamination (e.g. taint, odor, allergen, component transfer from inks, varnishes and glues)
- potential problems arising from the use of recycled materials
- 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
- potential for malicious intervention.
I attach a template I used.
After working with food only for the longest time, it was eye opener what to look for when approving packaging suppliers now. Hope it helps, also no CCP's identified this side.
Thks yr attachment.
I am not directly familiar with Packaging or the SANS FS Standard but i suspect it owes some of its content/structure to iso22000.
I much admire the effort/organisation that went into yr (afaik) relatively novel PIGS/haccp presentation but I would make a few comments on the ultimate result as shown -
(a) Mixes together Safety/non-safety evaluations. maybe this is Packaging / SANS-HACCP required but not a (currently) typical (food) haccp hazard analysis IMO.
(b) you have set the impact (severity) for every hazard at 1 (ie ~ negligible) !!! For example, incorrect printing as per customer specification. This is surely implausible..
(c) Your PRP of "Supplier Control" might be more appropriately designated as "Supplier Approval" IMO.
(d) Seems to me you you have defined some control measures only in a general way, eg specification management. I believe a control measure for a process step needs to be specific to the identified "hazard" unless it is being controlled by a PRP.
(e) The format does seem ultimately to generate a rather laborious (= 6pgs) methodology in comparison to a traditional 1 page hazard analysis ?.
Nonetheless, it's an impressive "work of art/science".
PS - Rightly or wrongly, IIRC (eg Post 7) some other haccp packaging plans do succeed in finding some CCPs. It's all subjective of course.
Edited by Charles.C, 29 June 2017 - 10:35 AM.