HACCP for Secondary Packaging

Hello, I am new to this forum and am looking for some information on CCP for secondary packaging. At this point in time we have no CCP for our processes, any issues are covered under our prerequisite programs. We take prepackaged material and put it into display units to go to a DC. Do I need to list these as an exhibit? We have numerous control points, any help would be greatly appreciated. Also if any one knows of a place where I could get my HACCP plan reviewed, that would help also. Thank you so much.

Hello:

I'm in a similar situation. Our product is indirect contact. Do you get audited by your customers or third parties? HACCP is typically one of the areas that is in an audit, so they'll look at your process flow. I've found them to be helpful and a good source of information, you could run it by them. They've said that based on our current product, there are no CCP's in our process, but we need to review our plan on an annual basis to determine if anything has changed.

If I understand your post correctly, you have two distinct processes:

1. The manufacture of display units
2. The filling of these display units with pre-packaged products (foods or non foods?) for dispatch to customers.

If so, you should carry out a hazard analysis on both of these processes, ideally as separate exercises.

For the manufacture of the display stands, whilst it is probable that you will not identify any CCPs, typical hazards to evaluate may be:

-Mixing of printed designs so that the unit is correctly displaying information related to the product it contains.
-Ink drying so that text does not become illegible or comes off on customers
-Correct design so that the unit is capable of withstanding the weight of the product durung filling, transport, storage and display.
-Correct manufacture so that the strength requirements are met. (eg ensuring that any corrugated fluting is in the right direction, glue application etc)

For the filling of the units, the hazard analysis must be sufficient and flexible to identify and control any risks associated with the specific products being filled, but again, unless you are packing chilled food products, which is probably not the case, there are unlikely to be any CCPs. Possible hazards may be:

-Mixing of products within the unit
-Damage to pacakging
-Allergens

Be careful how you do your hazard analysis. If you use a food HACCP model, where only chemical, physical and microbiological hazards are normally evaluated, you will not look at the functional hazards of your products which are more likely to occur.

If you put up your analysis we can comment, hopefully constructively.