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#1 HPG

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Posted 09 September 2011 - 08:02 AM

Dear all,

I do hazard identification for primary packaging that used for our products. and I only identified for microbiological (TPC, E. coli, Koliform) and physical hazard.
What else do you think I should include in hazard identification?

Please advice.
Regards,
Hadi


Edited by HPG, 09 September 2011 - 08:04 AM.


#2 Charles.C

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Posted 09 September 2011 - 05:51 PM

Dear all,

I do hazard identification for primary packaging that used for our products. and I only identified for microbiological (TPC, E. coli, Koliform) and physical hazard.
What else do you think I should include in hazard identification?

Please advice.
Regards,
Hadi


Dear HPG,

IMEX none of yr quoted micro. parameters are pathogenic, ie not haccp - relevant.?

Is it plastic or cardboard ?

The intrinsic risk aspects (PBCA) are normally defined through the detailed purchase specification, ie the responsibility of the supplier via a COA.

And add on the process risks at reception / storage / deboxing etc.

For the second one, can get an idea of the potential risks to be controlled at receiving packaging / .... et seq from the excel sheet in post #66 of the ISO 22000 yoghurt thread. Although i anticipate that you know all that stuff already ;).
(from an ISO 22000 / PAS220 point-of-view, I guess most of the risks are controlled by PRPs)

Rgds / Charles.C

Kind Regards,

 

Charles.C


#3 HPG

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Posted 10 September 2011 - 01:59 AM

Dear HPG,

IMEX none of yr quoted micro. parameters are pathogenic, ie not haccp - relevant.?

Is it plastic or cardboard ?

The intrinsic risk aspects (PBCA) are normally defined through the detailed purchase specification, ie the responsibility of the supplier via a COA.

And add on the process risks at reception / storage / deboxing etc.

For the second one, can get an idea of the potential risks to be controlled at receiving packaging / .... et seq from the excel sheet in post #66 of the ISO 22000 yoghurt thread. Although i anticipate that you know all that stuff already ;).
(from an ISO 22000 / PAS220 point-of-view, I guess most of the risks are controlled by PRPs)

Rgds / Charles.C


Dear Charles,
thks for your reply
I've already read your attachment.
And I see that for M&CA, you use supplier spec.

The primary packaging is metallized plastic.
The supplier for this packaging is part of our group company (but didn't include with our ISO 22k system).
How about solvent? eventhough it's not include in specification, should I mention in hazard identification?


Regards,
Hadi

Edited by HPG, 10 September 2011 - 02:23 AM.


#4 Charles.C

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Posted 10 September 2011 - 08:05 AM

Dear HPG,

And I see that for M&CA, you use supplier spec.


Actually “A” is a bit more expanded. But maybe not relevant yr set-up.

For M,C - Yes because there is usually no real-time tests available except for visual inspection (ie P).
Some factories sample / monitor things like thickness, artwork details, etc but these are non-haccp.

personally, MEX is mostly with simpler packaging than yours so I hv used a "blanket" generic "food grade" specification (eg USA CFR sections) within a preliminary intro to the individual haccp plans (plus the style in my excel sheet). This partially avoids auditor nit-pickings into details. Not sure is possible for yr type of packaging though.

Metallised plastic not really my product area so I don’t know much but most “simple” plastic packaging is manufactured at high temps so eliminating micro. risk (assuming subsequent GMP is maintained).
Also, in many locations, the final customer (for his own legal protection) requires copies of official certification guaranteeing the intrinsic packaging safety. This may involve data from the user (ie you) / bag manufacturer / plastic supplier. The full details are typically defined by the customer’s regulations / yr local regulations, and can vary of course. The latter should be your packaging provider’s job really but I agree that in many cases I hv had to get the testing requirements for them and occasionally organise it myself (they tend to be suspicious that competitors are involved).

The supplier for this packaging is part of our group company (but didn't include with our ISO 22k system).


So no supplier audit data ? Nice auditor :smile: .

How about solvent? eventhough it's not include in specification, should I mention in hazard identification?


The more meaningful question is probably “should it have been included in the specification”.
Should pass onto the packaging experts here, AND maybe yr in-house provider.

PS My curiosity again :smile: . Did you design a similar 7.5.3.2 response in yr ISO 22000 system to my excel sheet layout or did you simply list/locate/give values of the most haccp-relevant process control measures, ie not including / detailing all the PRP-related stuff.

Rgds / Charles.C

Kind Regards,

 

Charles.C


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#5 HPG

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Posted 12 September 2011 - 03:34 AM

PS My curiosity again :smile: . Did you design a similar 7.5.3.2 response in yr ISO 22000 system to my excel sheet layout or did you simply list/locate/give values of the most haccp-relevant process control measures, ie not including / detailing all the PRP-related stuff.

Rgds / Charles.C


The first time I made HACC Plan, I didn't include hazards that have already controlled by PRP.
But, when audit ISO 22000 for the first time, the auditor recommend to include all hazards, eventhough those have already controlled by PRP.


Hadi

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#6 Thomas Dunn

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Posted 12 September 2011 - 12:36 PM

Dear all,

I do hazard identification for primary packaging that used for our products. and I only identified for microbiological (TPC, E. coli, Koliform) and physical hazard.
What else do you think I should include in hazard identification?

Please advice.
Regards,
Hadi


It is unfortunately possible that producers of primary packaging can unintentionally mix lots of packaging for different stock keeping units (SKUs) To the extent that some SKU labels may declare allergenic ingredients and other the lack of these, failure to identify mix-ups can place "mis-labled" and "adulterated" product into consumer markets. The best way to monitor and avoid this problem is to provide active, real-time bar-code scanning on packaging lines to compare each printed package with the intended SKUs code.

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#7 Charles.C

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Posted 12 September 2011 - 02:32 PM

Dear HPG,

Thks for the comments. i deduce that yr original shortened version was considered acceptable but was "recommended" to be expanded into PRPs. I asked because i read an auditing company's proposed interpretation of the requirements for this clause and it included the text -

This clause produces an abundance of valuable documentation through which auditors can come to understand the processes involved and the identification of issues for hazard analysis.

Very suspicious! :smile:

I discovered that the CFR link I mentioned in earlier post seems to hv now vanished and the site has become an electronic maze to navigate. :thumbdown:

To answer yr question and "update" my generic zigzag, it seems to me that the very nice links in this thread

http://www.ifsqn.com...dpost__p__35333

should help, eg the material must be food grade within the context of (EC)No1935/2004 and related directives . An initial para. of the above reg. states that

The principle underlying this Regulation is that any material or article intended to come into contact directly or indirectly with food must be sufficiently inert to preclude substances from being transferred to food in quantities large enough to endanger human health or to bring about an unacceptable change in the composition of the food or a deterioration in its organoleptic properties.


Unfortunately yr metallised packaging might not yet be specifically included in the above set of directives according to one ref. I looked at (f2) although the principle is presumably maintained. I hv attached 3 additional refs which I found quite interesting below however Rosie's is probably the most-up-to-date (2009) for the EC scene. The f3 document illustrates how the same format style is used when oriented to Australian/NZ application.

Based on the material above, and the example lid specification in Simon's post, i daresay the answer to yr original question is no but i am quite willing to be contadicted. :smile:

Attached File  f1 - specifications-in-the-food-packaging-chain.pdf   139.93KB   236 downloads
Attached File  f2 - Food_Contact_Materials_and_Packaging_Legislation_Overview.pdf   32.13KB   221 downloads
Attached File  f3 - woolworths packaging spec paperboard - Folding_Cartonboard.pdf   35.51KB   153 downloads

Rgds / Charles.C

PS you might find the file g1 in parallel thread (generic packaging haccp plans) interesting also although this is somewhat differently oriented.

PPS - the PET specification of the plastic pot in the yoghurt thread might also interest you when it eventually appears.

Kind Regards,

 

Charles.C


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#8 Juhann

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Posted 16 September 2015 - 06:47 AM

Hi Charles

 

Thanks for the guidelines on packaging  Part 1.

I have done a google search in terms of articles where Part 2 were pubished, but could not find any links to these documents, by any chance you have the guidelines for Part 2 which relate to bottles with narrow openings made of glass/plastic. Thanks again.



#9 Charles.C

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Posted 16 September 2015 - 10:00 PM

Hi Charles

 

Thanks for the guidelines on packaging  Part 1.

I have done a google search in terms of articles where Part 2 were pubished, but could not find any links to these documents, by any chance you have the guidelines for Part 2 which relate to bottles with narrow openings made of glass/plastic. Thanks again.

Hi Juhann,

 

My apologies but i was unable to work out which item was the Part 1 you refer to above. Please clarify.

 

PS - Welcome to the forum ! :welcome:


Kind Regards,

 

Charles.C


#10 Simon

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Posted 17 September 2015 - 05:54 AM

In food packaging you also need to consider the chemical make up of the product itself and potential to migrate those chemicals into food above limits prescribed in regulations such as 10/2011.  You also need to consider chemical used in the process that can intentionally or unintentionally come into contact with product.  Also consider allergens and print defects affecting quality/safety (e.g. ingredients list on packaging), mixing packaging and defects that affect integrity such as holes in packaging if it is meant to provide a functional barrier for example.

 

Regards,

Simon


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