6 replies to this topic

[rosie]

Hi there

I would be intersted to know your thoughts on print verification on packaged products.
In our process we have three stages where we can ensure correct print is applied to product:

1. We set up a trolley prior to the run containing all that is needed for the run i.e. printing plates, customer spec etc
2. We place all new stuff onto the machine according to the customer spec
3. We check the first off product.

I have always been trained that the last step should be the CCP but this is the most difficult stage to carry out when looking at all of the information that needs checked by one person. Surely the critical stage ie setting the trolley up right but again this depends on one person checking lots of information.

Anyone any thoughts. Thanks

[Tony-C]

Hi There

If the print quality is also a hazard then surely the last step has to be the key control point. In my experience of manufacturing 2 people would check and sign off at this stage.

Regards,

Tony

[rosie]

Thanks Tony

Its just that it is too easy to miss something when looking at a pot as there is so much to check. We were recently stung when the only difference between pot and spec was 227ml and 225ml - the operative had spent a long time checking all the ingredients, allergy advice, print quality etc. If there was an automated and fail safe way of verifying the print I would be happy but what concerned us at this stage was that we had not emphasised the check at putting the trolley together and setting the machine up as the wrong plate had been put on.

Rosie.

[Charles.C]

Dear RosieNI,

Operationally, I thought the most common scenario was to make a small trial sample, fax a copy to the user and ask for approval, ie pass the buck. Maybe "small" is not possible in your case.

This kind of risk prioritisation problem has been the source of many HACCP debates. An analogous situation can occur in food processes with series of sieves etc. Originally, people did use the “best correct at earliest point” argument and all of them were often marked as CCPs (from textbook memory). But this procedure was gradually “phased” out within the trend to minimise the total number of CCPs (so as to optimise focus amongst other things). Hence the present choice of last step.

I think the use of oprps in ISO 22000 partly attempts to re-address this jump from “no importance” to CCP.

Of course, you could always make the earlier position a (High Priority) Control Point, or even a pre-requisite function at a stretch though auditors might not be too keen on the latter.

Having experienced the (1-step down) situation over checking paper labels / authorising print runs, I agree, it can be a logistical nightmare sometimes and mayrequire a particular kind of dedicated, 6th-sense equipped, operator. + a backup at the end.

Rgds / Charles.C

[Simon]

1. When the print design is in development the customer would be sent artwork to approve
2. When print plates are made (outsourced?) and whenever replaced get the supplier to send an actual printed output of the design the plates will give and not just the print plates
3. Check the plates and print out on receipt
4. Store and handle plates well, in a bag, by item code, exceptional organisation and maintenance
5. Do not have shared plates across item codes
6. When there is a design change create a new item code and not a revision to the current item
7. Make the plate mounters check and record when issuing
8. Ensure printers have enough information and picture of design / first off to match the print job to
9. Have a second check by buddy or supervisor
10. Retained samples should be checked before filing
11. Have agood system for efficiently checking, cleaning and returning plates to the job bag
12. Train, monitor, review and improve

Lot's of checks and balances but no CCP's. It should be enough IMHO.

Regards,
Simon

[Peter Snopko]

You have raised any interesting point about packaging print and HACCP programmes.

Question: When did do the risk assessment as part of your current HACCP programme..this should have quickly identified a print CCP (maybe so long ago, that it wasnt included inthe review). When was the last time you did a fresh assessment and review of the HACCP programme?

I believe the print Prepress/Artwork process has a natural CCP. Where it fits depends on your HACCP risk assessment. Artwork laycards should also be digitally signed off (Adobe PDF electronic signatures best option), and include the full name, job title, company name for all the approvers...packaging vendor and customer.

The packaging Print /Art design needs not only to be the correct version for quality management, but also needs to be food safe for the ingredients and allergen panels. If there are nuts or traces of nuts and this is missing because someone used the previous old redundant version, which didnt say "nuts", then you could kill someone. That is a sobering wakeup call.

Hope this helps
Peter

[carine]

I was wondering why  label printing step consider as a hazard or CCP? We just have final inspection on our  finished product to check whether production batch has been print correctly.