52 replies to this topic

[MartLgn]

The decision tables gave to much room for interpretation and unwanted discussion. Definitions of score based systems are straight forward and leave less room for discussion.

Okido.

I understand that the methodology of score based risk assesment is a sound one but the point you make about removing discussion is the part of it that I have never been comfortable with. If we are determining a score by assessing likelihood and severity then surely determining those factors relies just as much on peoples own opinion and interpretation as would the application of a decision tree ?
One person may think the risk is high, another moderate yet these views must be distilled to produce a definitive score ( ' we can't have 2.5 it is either 2 or 3 ' ) , IMO this is no less subjective than a decision tree.
It obviously works for your company and your auditors and of course the most important indicator is the safety of the end product, perhaps us Northerners like an argument too much to want to remove the discussion from the process altogether

[Simon]

It's two

Its' three

It's two

It's three

It's two

It's three

It's 4. Come on let's go down the pub.

[Charles.C]

Dear All,
Since this thread has somewhat broadened (to the pub) don't forget that the hazard analysis is supposed to be validatable (presumably including the scoring systems).
Most evaluations tend to (perhaps wisely) by-pass the hard realities of raw data. If you want to see some heavier text (300+ pgs) try the full-featured quantitative risk assessment at

http://www.fao.org/a...lmonella_en.stm

covering -
(1) S. Enteritidis in eggs, the risk characterization estimates the probability of human illness due to S. Enteritidis following the ingestion of a single food serving of internally contaminated shell eggs, consumed as either whole eggs, egg meals or as ingredients in more complex food (e.g. cake).
(2) Salmonella in broiler chickens, the risk characterization estimates the probability of illness in a year due to the ingestion of Salmonella on fresh whole broiler chicken carcasses with the skin intact,and which are cooked in the domestic kitchen for immediate consumption.

This reference also contains an impressive summary of general data on known Salmonella-related food poisonings including the Xmas chocolate balls I mentioned in another thread. (There is some allowance for the ability of one person to safely eat a whole 1lb bag of uncontaminated chocolate (well-spotted earlier by Yorky)).
Rgds / Charles.C

[MartLgn]

Dear All,
Since this thread has somewhat broadened (to the pub) don't forget that the hazard analysis is supposed to be validatable (presumably including the scoring systems).

Charles.

I totally agree that it is necessary for a Hazard Analysis to be validated, as for the salmonella et al, don't forget that the thread refers to CCP's in packaging manufacture where converted foodies like myself do not always have such lavish data to refer to when determining hazards, which results in the discussion and interpretation which Okido referred to thus resulting in more frequent trips to the pub

[Charles.C]

Dear MartLqn,
Sorry, it was a rather large off-topic. My only defence is that I had given up waiting for anybody to answer Simon's original very interesting question. I seem to remember that the model packaging HACCP plan presented on this site ended up with zero CCPs. Neat.
Based on some unpleasant experiences, I usually select the 'receiving raw material of direct food contact, plastic packaging' as a CCP. This guarantees a discussion with the auditor. Can be literature validated if you search long enough.
Actually as you probably know detailed usable data on food safety incidents is also rare but its collation has certainly been promoted by HACCP. I deduce that data is even more scarce on packaging. I hope this is a comment that very few health incidents are statistically attributed to packaging defects ?
Rgds / Charles.C

[MartLgn]

Sorry, it was a rather large off-topic. My only defence is that I had given up waiting for anybody to answer Simon's original very interesting question. I seem to remember that the model packaging HACCP plan presented on this site ended up with zero CCPs. Neat.

I sense your frustration that the original question has been dodged Charles, I would like to draw a parallel with the frustration felt by those in the packaging industry charged with ensuring product safety through Hazard Analysis and associated methodology. The fact is that whether you use HACCP, decision trees or risk based scoring it is very difficult and in many cases impossible to identify CCP's (as defined in Codex) within the packaging production environment.

Based on some unpleasant experiences, I usually select the 'receiving raw material of direct food contact, plastic packaging' as a CCP. This guarantees a discussion with the auditor. Can be literature validated if you search long enough.

That is very interesting, what kind of hazards do you associate with this packaging ?

Actually as you probably know detailed usable data on food safety incidents is also rare but its collation has certainly been promoted by HACCP. I deduce that data is even more scarce on packaging. I hope this is a comment that very few health incidents are statistically attributed to packaging defects ?

I wouldn't pretend to know the instances of incidents attributed to packaging defects, the data I had in mind was that comparable to pathogen levels in food where one can take the prevailing scientific advice as a basis for setting your critical limits. Although EU law places limits of certain substances in packaging material the level of these substances tends to be constant in a given material and unlike pathogens the levels are not altered by subsequent processes such as cooking. The fact that most packaging materials have no potential to promote the growth of pathogens removes a major hazard source and is one of the things that stumps the ex foodie embarking on a hazard analysis study of a packaging process.

Its been a few years since packaging customers started asking for HACCP and the BRC/IOP standard arrived but IMO the methodology for identifying CCP's in a packaging environment is still far from fully established, there is no Codex Packagingus Commision and very little guidance out there. Type 'HACCP for Food packaging' into Google and the only worthwile return is Saferpak.Com I hope Simon won't think Im being presumptious but that lack of a definitive way to manage Hazards in packaging production is one of the main reasons for the existance of this site .

If it was easy to identify CCP's in the packaging environment then we would do so, the reliance on prerequisites may seem like a cop out but as this thread shows we strive to find the best way to identify and rate hazards so it's not through a lack of effort in the industry, rather its the nature of the beast.

Right thats the drum banged for the packaging boys and girls, Im off to the pub

[Charles.C]

Dear MartLqn,
Your comments prompted me to do some googling and I certainly agree yr statement about lack of packaging HACCP plans / incidents.
I appreciate yr disadvantage regarding lack of micro.baddies however seems there are plenty of chemical options - I noticed a compilation of ‘contaminations from packaging / L.Castle' with claimed HACCP orientation which looked quite promising.
http://www.jifsan.umd.edu/csl2003.htm

As a validation to using 'Receiving Packaging Materials' as a CCP can try this -

http://www.inspectio...kbrpou6ae.shtml

where the temptation to include it within the pre-requisite class was resisted ( this plan is relatively old but still well done IMO, also looks at allergens).

As you know, the typical literature critical limits are usually something like -
(a) Only food-grade packaging materials are used (can be as defined by 'US standard ….')
(b) Letters of guarantee from packaging companies on file.
© Specifications (linked to (a))
OK, it covers some of the back, can expand these items to requiring full clearance certificates, migration results, etc depending on material (plastic, aluminium…). Such information was never offered, always had to be laboriously extracted (the usual response was 'We have faxed our ISO 9k/2k certificate covering all processes').
You asked regarding my experience reasons for making a CCP, 2 examples -
(1) Probable mixing of recycled plastic pellets with good stock to make new plastic bags - result was bags which went brittle after few weeks at -20degC, either cracked open in transit or when handled.
(2) Slight increase of thickness of plastic bags, presumably to decrease supplier workload / kg (or poor machine maintenance to be generous) - result was degraded heat seal using standardised sealing conditions which also revealed itself at -20degC by opening.

Rgds / Charles.C

[Simon]

I wouldn't pretend to know the instances of incidents attributed to packaging defects, the data I had in mind was that comparable to pathogen levels in food where one can take the prevailing scientific advice as a basis for setting your critical limits. Although EU law places limits of certain substances in packaging material the level of these substances tends to be constant in a given material and unlike pathogens the levels are not altered by subsequent processes such as cooking. The fact that most packaging materials have no potential to promote the growth of pathogens removes a major hazard source and is one of the things that stumps the ex foodie embarking on a hazard analysis study of a packaging process.

Its been a few years since packaging customers started asking for HACCP and the BRC/IOP standard arrived but IMO the methodology for identifying CCP's in a packaging environment is still far from fully established, there is no Codex Packagingus Commision and very little guidance out there. Type 'HACCP for Food packaging' into Google and the only worthwile return is Saferpak.Com I hope Simon won't think Im being presumptious but that lack of a definitive way to manage Hazards in packaging production is one of the main reasons for the existance of this site .

If it was easy to identify CCP's in the packaging environment then we would do so, the reliance on prerequisites may seem like a cop out but as this thread shows we strive to find the best way to identify and rate hazards so it's not through a lack of effort in the industry, rather its the nature of the beast.

Right thats the drum banged for the packaging boys and girls, Im off to the pub

Enjoy your pint mate - brilliant post. You just about summed it all up for packaging. And yes that is why we are here - I don't mind.

Re your post Charles I need to have a look and digest - but got to dash just now.

Simon

[MartLgn]

I appreciate yr disadvantage regarding lack of micro.baddies however seems there are plenty of chemical options - I noticed a compilation of ‘contaminations from packaging / L.Castle' with claimed HACCP orientation which looked quite promising.
http://www.jifsan.umd.edu/csl2003.htm

Good Googling Charles
Thats a very in depth paper and it highlights an issue concerned with chemical contaminants as opposed to microbiological, namely that the hazard of Listeria,Salmonella etc to the vulnerable is well understood whereas the results of exposure to chemicals used in packaging materials are only apparent in the long term and in many cases still under research. The EU plastics directive prescribes limits of various chemical constituents on different types of plastics and yet for a HACCP team analysing the risk posed by a film there may be no current data on what happens when that level is exceeded so no informed judgement can be made on the level of risk posed. In circumstances such as these I would argue that the sensible method to manage the risk is to aquire supporting data and certification from the material supplier stating compliance with the relevant legislation.

As a validation to using 'Receiving Packaging Materials' as a CCP can try this -
http://www.inspectio...kbrpou6ae.shtml

where the temptation to include it within the pre-requisite class was resisted ( this plan is relatively old but still well done IMO, also looks at allergens).

I must admit I was suprised to see plastic bags as a CCP for the reasons listed above, although the legal limits form the critical limits I am still unsure as to how the level of risk can be determined unless the Canadian producer in question had current data on the exact risks posed by the materials of which the bags were composed.

As you know, the typical literature critical limits are usually something like -
(a) Only food-grade packaging materials are used (can be as defined by 'US standard ….')
(b) Letters of guarantee from packaging companies on file.
© Specifications (linked to (a))
OK, it covers some of the back, can expand these items to requiring full clearance certificates, migration results, etc depending on material (plastic, aluminium…). Such information was never offered, always had to be laboriously extracted (the usual response was 'We have faxed our ISO 9k/2k certificate covering all processes').

I totally agree with your assesment here, my company sends a comprehensive list of applicable requirements that must be returned with signed certfication of compliance and migration data where appropriate. Assuming accurate and up to date information can be dragged out of the supplier I think that this is currently the most viable method of ensuring compliance with the regulations for chemical contaminants in packaging materials. I know it seems that we are wedded to our prerequisite programmes in the packaging sector but wait till ISO 22000 really takes off amongst industry and we actually HAVE to have them

[Simon]

I pretty much agree with Martin. For food contact packaging materials I would require migration certificates (and test results) from the supplier as part of the supplier / material approval process and prior to purchasing. Once the specification is agreed and as long as nothing changes migration testing is not something that needs to be done per batch or even once a year. I would only expect fresh migration tests to be carried out if the applicable legislation changes or something new raises its head like ITX. I would also check up on the lab who perform the migration testing to see if they are Kosher - if it's someone like ISEGA you know they are OK. I've just created a question for myself; do these labs need to be accredited for migration testing and if so what should we be looking for?

Regards,

Simon

[okido]

Hi Charles:

You gave two examples for a CCP were I would like to now more about.
How did you use the bags, vacuum sealing, shrink / non shrink?
How was the seal strength controlled just by standard settings?

Best regards, okido

[Charles.C]

Dear Okido,

Nothing special process-wise except that I guess (the plastic people here will surely know more than me) that the basic raw material, LDPE, is already a bit composition special to be compatible with -40degC freezing + maintain integrity at -20degC storage. Hence the problem No1.
Sealing simply done by an automated heating strip system which I presume is standard gear. Set-up from manufacturer's specs / (trial and error) with basic evaluation by storage / 'rip test'. Hence the problem No2 in that the deviations caused a borderline seal.

Rgds / Charles.C

@ MartLqn,
I agree yr comment regarding difficulty in assessing risk for a packaging CCP. One risk matrix I found includes a score for 'Has this hazard ever happened to you' which enables a certain degree of creativity.
Rgds / Charles.C

Edited by Charles.C, 25 July 2006 - 05:46 PM.

[MartLgn]

One risk matrix I found includes a score for 'Has this hazard ever happened to you' which enables a certain degree of creativity.

Thats a nice question to ask not least because it shows that we learn from our mistakes, even though our Hazard Analysis team uses the Codex decision tree, the question of past experience is one that we considered when considering if a risk exists at a given step of the process. When discussing potential risks within a team or when justifiying a CCP ( or rather the lack of) the fact that ' this has never happened to us' is an important factor to be considered .

[Gaskit]

For a change I would like to ask a question if I may.

I know we get lots of visitors to the BRC/IOP Forum from different packaging processes (glass, metals, paper, plastics, wood) and I would like to know some details on your HACCP (hazard analysis) especially the additional hazards you have identified (if any) over and above the requirements contained in the Standard.

If you have identified Critical Control Points please tell me what they are and how you control them? If you haven't identified any CCP's again please post as it will be useful information to me.

Thanks for your help,
Simon

Dear Simon,

Just to re-open this thread again, I have attached a copy of HACCP plan for one of our die cutters (NO CCPs) has anyone got any views about it. I have combined all pages onto one document on the original they are all controlled singal paged documents.

Regards,

Steve

Attachment corrupted - removed from post.

New link added / Charles.C / 10022008 -

 gaskit_saferpak_RotacuT.doc   89.5KB   267 downloads

[Chakos]

Hi,

I am preparing for BRC certification Packaging - for a carton manufacturer and have read the discussions ref identifying CCPs etc. In July 06 Charles C refereed to a "Model HACCP Plan" for packaging that was presented on this site, could you guide me to it.

Thanks

Chakos

[Charles.C]

Dear Chakos,

The thread is -

http://www.ifsqn.com...p?showtopic=355

1st post by Simon has the dwl link to HACCP plan.

Other possibly useful documents including the above are reached by -

Go to forum “General discussion”

Clicking subforum ‘document exchange” gives you a selected list of theads with dwl packages.

(Three up from the bottom is "Haccp Manual Example for Packaging" started by Simon as given above)

Click to open any thread.

(The third from top, "Food Packaging Hygiene Documents" also contains the same HACCP plan and some excellent model SOPs as well)

Rgds / Charles.C

[Chakos]

Thanks Charles

[Gaskit]

Hi all,

I don't believe that I have missed posting on this thread. I used to have nearly every process marked as a CCP i.e; SUPPLIER, INTAKE,DIE CUTTER PRESS, PALLETISE,CODE and DESPATCH (up until gaining insight from other threads) then I controlled all the above with PRPs / OPRPs with the exception of INFEED to the die cutter press which drags board into the machine with "gripper pins" and these occasionally break hence keeping as CCP.

Basically I have reduced all CCPs to 1 throughout the company processes and have passed the BRC re-inspection with no problems.

Kind regards,

Steve

[Tom M]

Simon,

Also the files in this thread gave an error.


Regards,

Tom

[Simon]

Simon,

Also the files in this thread gave an error.


Regards,

Tom

Hi Tom, a few members have mentioned having problems when downloading some attachments. Unfortunately it appears that some attachments have been corrupted by a recent software upgrade. This is a known bug with the software provider, but unfortunately there is nothing they can do to retrieve the broken attachments. The only thing we can do is report them when we find them in a thread. I will delete them as we go along. I'm hoping it only affects a small number of attachments.

Apologies for the inconvenience

Regards,
Simon

[Charles.C]

Dear All,

Laura's early posted uploads are unfortunately broken. I think the links 1,2 below are the correct replacements -

1.  laura_Copy_of_saferpak_dwl_140706___risk_assess.xls   19.5KB   110 downloads

2.  laura_saferpak_dwl_140706_risk_cat.doc   26.5KB   73 downloads

added - hv also put in new link for Gaskit post of 18 April 2007

Rgds / Charles.C

[FRAZA]

Hi Simon, said i would be on here a lot once i could get signed in. I am from a packaging company. We have one ccp from our haccp and it is the cutting and creasing the cartons, this is due to the nature of the tooling. It is made up of wood and metal parts which are bolted, screwed on and we have had a few issues internally with pieces being dislodged and falling into the product piles. Some cartons go out flat on pallets so we would not pick this up before it leaves. I have attached a copy of our haccp if useful.

Any comments appreciated

Attached Files

•  HACCP_07.xls   268.5KB   160 downloads

[Simon]

Hi Simon, said i would be on here a lot once i could get signed in. I am from a packaging company. We have one ccp from our haccp and it is the cutting and creasing the cartons, this is due to the nature of the tooling. It is made up of wood and metal parts which are bolted, screwed on and we have had a few issues internally with pieces being dislodged and falling into the product piles. Some cartons go out flat on pallets so we would not pick this up before it leaves. I have attached a copy of our haccp if useful.

Any comments appreciated

Thanks for posting Fauzia, I will have a read and revert with comments later.

Regards,
Simon

[Charles.C]

Dear Fauzia,

Thks for this generous and interesting presentation. Certainly very compact style while still allowing a lot of detail . Presume there is some header or footer info. on the actual document unless my computer has chosen to not display it.

Still digesting (not a packaging person) but hv a few initial queries –

1. I presume the item referred as CCP1 is the CCP you mention. Don’t quite understand why the risk evaluation = 4 which is < CCP as per yr stated decision matrix. (The critical limit (failure determined how ? visually?) and monitoring (>> audit comment) also look a bit strange.) Maybe I’ve simply misunderstood .
2. Also on same page, Nos 43 – 45 appear to suggest that 2x1 = 3 ? Maybe this is not the last version ? (rather surprised no changes for 1.5 yrs after Ver1).
3. I notice that none of the mentioned SOPs etc hv any numbering to crosslink elsewhere. Do I understand correct ? (Rather unusual IMEX although not unique). Or perhaps this is just an overview document ?
4. Sorry for ignorance but in the “Process Flow” page, what is the meaning of “PBO” in Step 12 ?
5. In the “Process Flow” page, any particular reason for showing the particular (red) items designated 14,15 on the flow as against other GMP-type possibilities. ?

Many thks again for opportunity to see yr plan.

Rgds / Charles.C

[Albert Chambers]

Simon

The Packaging Association of Canada (PAC) has developed new PACsecure voluntary food packaging-specific safety standards designed to help packaging converters harmonize with the international protocol long used by the global food and beverage industry: Hazard Analysis Critical Control Point (HACCP). The website for this program is: www.pac.ca/Services/HACCPhome.html The 70 member committee that developed these standards represented a cross section of manufacturers and users, including a significant number of multi-national food companies. It is anticipated that PACsecure will be reviewed and recognized by the Canadian Food Inspection Agency when its recognition program for industry-led HACCP-based programs in launched (this will mirror its existing recognition program for on-farm food safety programs).

As of early 2008, the following modules are available to PAC members and to non-members:

Generic Food Safety – Prerequisite Program

Standards
Workbook

Flexible Plastics – Generic HACCP Plan

Standards
Workbook

Rigid Plastics – Generic HACCP Plan

Standards
Workbook

Paper – Generic HACCP Plan

Standards
Workbook

In preparation and expected to be released later in 2008 are:

Metal

Standards
Workbook

Glass

Standards
Workbook