7 replies to this topic

[COQA]

Hi,

I am the QA coordinator for a pressure sensitive label manufacture. One of my clients would like us to develop a HACCP plan. I have spent the last week reading everything I could get my hands on to develop this plan.

I am interested in opinoins on what would be classed as a CCP for a label maunfacture.

Currently I have:

1. Incorrect print due to prepress or plates
2. label mix up during the finishing stage.
3.Contaminates such as oils, hair, metal & pests.

Any help would be appreciated.

Thanks

[Simon]

I am the QA coordinator for a pressure sensitive label manufacture. One of my clients would like us to develop a HACCP plan. I have spent the last week reading everything I could get my hands on to develop this plan.

I am interested in opinoins on what would be classed as a CCP for a label maunfacture.

Currently I have:

1. Incorrect print due to prepress or plates
2. label mix up during the finishing stage.
3.Contaminates such as oils, hair, metal & pests.

I'm sure you have already seen the HACP plan below, that one is for a supplier of food contact packaging and labels are less of a risk. It is unlikely you would have any CCP's in your process with most hazards being controlled sufficiently by GMP's or prerequisite procedures. Maybe print control measures or preventing mixed labels could be considered critical as it could be a serious problem if ingredients were missing or incorrect. I think you will find the plan below of some use. Please feel free to ask further questions.

Example HACCP Plan for a Direct Food Contact Packaging Manufacturer

Regards,
Simon

[Charles.C]

Dear COQA,

Not my area but is this label potentially applied directly to food ?

If so, the adhesive is presumably relevant. I remember this aspect being discussed here before.

(usually helps to provide some details of application but perhaps it's obvious here in which case my apologies)

Rgds / Charles.C

[COQA]

Thank you both for you help.

Simon, Yes I did look at the guide that was posted and am actually using it to develop the plan.

Charles, We have both direct and indirect food contact labels of which only the apple labels have adhesive. the rest are package inserts So I guess I'll also have to look at inks too.

[Charles.C]

Dear COQA,

So I guess I'll also have to look at inks too.

I guess yes. You can try the extended discussion here although some of the regs may hv changed since ca 2007 -

http://www.ifsqn.com...?showtopic=6221

The details will obviously depend on local requirements.
(I believe in Canada you hv a very comprehensive official system to define approved food contacting chemical possibilities ?) (I noticed in passing this topic-unrelated thread but with a lot of Canadian input http://www.ifsqn.com...?showtopic=6869 )

Rgds / Charles.C

[okido]

Hi COQA,

I would not expect any ccp's in a printing department.

Some point of attentions are:

* ink, heavy metals etc
* migration of solvents
* set off (gmp regulation in the EU)
* cutting off blades for anilox
* wrong print >> gmo and allergene prints
* high value of solvent retention

Have a nice day, Okido

[Salamony]

* wrong print >> gmo and allergene prints
Y it's not CCP?




[/quote]

[Charles.C]

Dear COQA,

The very detailed packaging (Kraft) HACCP plan attached below although not specifically for labels seems relevant to several of the factors being discussed in this thread and the previous post.

 KraftPkgHACCP_KFExample.doc   606KB   144 downloads

Particularly see the CCP1, inks and allergen aspects. I noted the HACCP idea of sharing part of the CCP to the customer via a proof confirmation step. Although this is a standard check (and often demanded by the customer), including this as part of the processor's HACCP plan seems a debatable concept to me although i suppose it’s analogous to asking for certified statements regarding quality of raw materials in the pre-requisite HACCP section.

It maybe subjectively comes back to your (CCP) risk analysis of course plus how you interpret pre-requisites. And the validation.

Regards / Charles.C