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maiwaldt

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Posted 15 August 2005 - 09:44 PM

Hello to all,
i'm an auditor from germany working for a certifcation body in germany.

i was selected to become a brc/iop audtior. for my accreditation i have to write an assignment about plastic and paper/board packaging.

Paper is no problem for me because i've made a lot of FEFCO-GMP certification audits at corrigated board manufactures.

But i've a little problem with plastics.
One of the tasks is a fictive audit at a company producing plastic bottles for direct food contact. The HACCP-study of the company contains no CCP's as the management team consider that there are no (real) CCP's in their process (as defined by the requirements of the Standard), and that the quality and integrity standards of their product are met by normal production controls and good manufacturing practice (GMP)

I've to review and comment on how i would accept/reject this argument.

I make an assumption that the company only produces preforms/parisons for plastic water bottles that will be stretch-blow-moulded just befor filling at the well-company.

I' would accept the arguments of the bottle producer because in my opinion they don't have any ccp's.

What do you think about it? Is there any (real) CCP in Plastic bottle productionor not?
For me a CCP is a point of control to prevent contaminations/hazards in food which can do harm to the consumer.

Thanks,
Thomas

P.S. sorry for my english



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okido

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Posted 16 August 2005 - 06:59 AM

Hi Thomas,

It is possible that there is no CCP, but I would have some questions. :uhm:
Have a close look at material use, especially the layer that comes in direct contact with the water. Is it a material with a specific or global migration limit?
Is the limit < 1 mg/6dm² than you come rather close to a CCP.
Do they take these migration limits into account in their HACCP method.
What if materials are change by accident, do you notice this in processability?
Are there reaction products likely in extrusion when materials are processed at wrong temperatures or wrong combinations are used.
Are there any additives used in the layer that comes into contact with the water. If so can overdosing be a source of contamination.
Do they use food grade oil in their compressed air system?
Is the compressed air microbiological safe?
Are the preforms packed in hermetically closed bags to prevent contamination during transport.

Okido,

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Simon

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Posted 16 August 2005 - 06:50 PM

I make an assumption that the company only produces preforms/parisons for plastic water bottles that will be stretch-blow-moulded just befor filling at the well-company.

<{POST_SNAPBACK}>

Why do you make this assumption is there not enough information provided?

I think the only real risk of harm to the consumer would be as Okido says chemical migration from the raw material. You would expect to see evidence of strong supplier quality assurance and the plastic consistently meeting all relevant (EU) food contact legislation. If the bottles are sold as aseptic then there may well be a CCP or two e.g. is there a sterile bottle storage tank? And how do they assure aseptic through production and delivery processes?

I have to admit I'm no expert in this process.

Can anybody else help out?

Regards,
Simon

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Charles Chew

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Posted 17 August 2005 - 12:18 AM

Type of plastics you are referring to would help .....PET?

However, the opinion from Okido is IMO basically the only issue you would be looking at i.e. migration of chemical hazards eg acetaldehyde, heavy metals, metabolites etc.

Some chemical migrations are in the form of gas which can be removed by allowing it to "breath". Unless physical residues are left behind, this would be a concern but is generally okay if you are dealing with food grade substances. Leaching at certain temperature during use is also a concern from plasticizer materials.

Charles CHew


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okido

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Posted 17 August 2005 - 12:14 PM

You would expect to see evidence of strong supplier quality assurance and the plastic consistently meeting all relevant (EU) food contact legislation.


Major plastic suppliers provide compliance statements against EU and FDA legislation. Also batch data with relevant information is provided.
Although this gives a certain degree of assurance it still is necessary to test on migration of chemicals out of the final product.
Does your fictive company with a very interesting process (I would like to patent it) do testing on migration.

Okido,

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Franco

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Posted 17 August 2005 - 02:19 PM

... it still is necessary to test on migration of chemicals out of the final product.


I don't think so: what can happen if the final product is water and only water, Risk Assessment has been perfomed with no CCP's and plastic production process is standardized and validated ? :uhm:

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Posted 17 August 2005 - 06:29 PM

Could aseptic be a factor or not for water?


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okido

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Posted 18 August 2005 - 06:42 AM

What can happen if the final product is water and only water


I do not regard water as the final product. The final product for me would be the blown bottle. And I think that a migration test is still neccesary on the bottle.

Okido,

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Franco

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Posted 18 August 2005 - 07:05 AM

I do not regard water as the final product. The final product for me would be the blown bottle. And I think that a migration test is still neccesary on the bottle.


This thread is connected with the other on the definition of quality.
Quality of the blown bottle is not a characteristic of the bottle itself, but it depends on the liquid: think of spirits, oil or water. The migrating chemicals from the container wall to the liquid are different in different liquid media.
As a matter of fact, there are different tests according to the final use of the bottle.
In the end, you must specify the destination of your end product (see also HACCP principles). This is why I said that if HACCP and RA have been performed properly and the process is standardized and validated, you don't need anything.

Just my two pennies.

An ancient Chinese proverb teaches that the person who waits for a roast duck to fly into their mouth must wait a very long time.

Charles Chew

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Posted 18 August 2005 - 03:03 PM

Franco,

different tests according to the final use of the bottle.



I share the same view.

Charles Chew

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maiwaldt

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Posted 21 August 2005 - 02:41 PM

thank you for the information, you have helped me a lot.



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Posted 22 August 2005 - 12:23 PM

thank you for the information, you have helped me a lot.

<{POST_SNAPBACK}>

So what are your conclusions? How would you propose to review and comment on how you would accept/reject the argument?

Regards,
Simon

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maiwaldt

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Posted 27 August 2005 - 11:54 AM

I will publish the assingnment if it is rated and i got the result from the PIABC / IOP.

I'll accept the argument but the company must fulfil some basics and procedures.

Regards,
Tom




So what are your conclusions?  How would you propose to review and comment on how you would accept/reject the argument?

Regards,
Simon

<{POST_SNAPBACK}>



pacepavicius

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Posted 11 September 2005 - 06:38 PM

Hello, this is my very first post on a chat room of any description - I lead a very sheltered life.

I have been an active UK-based BRC / IOP evaluator since the publication of the first edition in 2001 and have 180 evaluations to my credit.

The question of CCPs causes a lot of concern and many companies tie themselves up in knots over the issue. In my experience, the number of CCPs identified can vary enormously - from zero to 50+ - but my contention is that it could / should be possible for packaging manufacturers to keep the level to zero or very close to zero. Let's not forget that we are involved in the manufacture of packaging and not in the preparation and handling of food so it is important to keep everything in proper perspective.

When dealing with PET preforms and bottles, there are two essential issues, over and above general hygiene and cleanliness. Firstly, the preform is injection moulded at high temperature and, if a two stage process, is re-heated to high temperature before the final stretch blow moulding process, so provided good standards of hygiene are employed during and after moulding, then there shouldn't be a problem with bacterial contamination. Secondly, acetaldehyde is produced as a by product if the resin is not dried sufficiently before moulding which can give an off flavour in mineral or spring water. Note that I haven't made any remark so far about the resin itself. PET is generally accepted as being an inert material (notwithstanding the issue with acetaldehyde). That is not to say that the appropriate food safety certificates aren't important, but it is extremely unlikely that the material would be unsuitable for food contact. The material is not altered in any way during the stretch blow moulding process other than the fact the molecules are oriented in such a way which improves the carbon dioxide and to a lesser extent the oxygen permeability, which makes PET an ideal material for soft drinks and waters, but not very good for beers.

I'd be fascinated to hear how you get on in your dissertation as I used to be a tutor and lecturer on the Institute of Packaging's diploma course.

Regards

Peter


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Simon

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Posted 11 September 2005 - 07:18 PM

Hello, this is my very first post on a chat room of any description - I lead a very sheltered life.

<{POST_SNAPBACK}>

Hello Peter, well I guess we're honoured. :beer: Thanks for your expert comments, I'm sure Maiwaldt will find them very useful.

Regards,
Simon

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maiwaldt

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Posted 21 November 2005 - 04:48 PM

Hello,
as promised i'll send you my two assignments for my certification as brc/iop auditor.
They need a loooong time to mark these two assignments (about 2 months)

You helped me a lot to pass the two assignments. I got good informations in this forum.
I pass the plastic with 65% and paper with 75%

Maybe the two assigments can help you a little bit about the way brc/iop is "thinking" and "working"

Kind regards
Thomas

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Simon

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Posted 21 November 2005 - 09:21 PM

Congratulations on passing Maiwaldt and thank you so much for posting your interesting assignments. I read both of them all the way through. I think maybe you got a lower score on the Plastics assignment because you used a large piece of information form the SaferPak website. Bad mistake. :whistle:

Anyway well done I hope you can stick around and share your experience.

Regards,

Simon


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