6 replies to this topic

[Peter Snopko]

If you are struggling with putting a HACCP programme together for your packaging manufactruing site, have a look at the FSAP (Food Safety Alliance for Packaging), working group of the IOPP (International Orgranisation Packaging Professionals).

They have a very interesting web site containing a number of different HACCP models, for various packaging types, ie cases, flexibles, rigid plastics etc.

So instead of starting from scratch, you can use these models and edit to suit. You still need to do the risk assessments and decide which CCPs you need to have, but it will shorten the whole process and take all the confusion away, which I see all the time.

Also remember to include the Artwork / Prepress to plate process in the risk assessment as there is a natural CCP in there!!!!!!!

FSAP web site address is: http://www.foodsafet...orpackaging.com

They also have a list and descriptions of the prerequist programmes / procedures to support the HACCP programme.

Looking forward to see how handy you find these models, so let me know how you get on.
Cheers
Peter

[Charles.C]

Dear Peter,

You're right, in fact there are a number of items from this site borrowed onto this forum.

Well worth another mention though

Have to say that as a non-packaging person, don't think i hv ever seen a "simple" HACCP packaging program other than the procedure originally posted here by Simon but that one is presumably completely outmoded these days and was not designed to go into all the minutiae of plate / plastic / artwork defects etc.

Rgds / Charles.C

[Peter Snopko]

Hi Charles
Thank you for the feedback.

I have found most packaging vendors in this part of the world really struggle putting a HACCP programme together.

What they also often forget is the formal HACCP training for the HACCP team members!

Cheers
Peter

Dear Peter,

You're right, in fact there are a number of items from this site borrowed onto this forum.

Well worth another mention though

Have to say that as a non-packaging person, don't think i hv ever seen a "simple" HACCP packaging program other than the procedure originally posted here by Simon but that one is presumably completely outmoded these days and was not designed to go into all the minutiae of plate / plastic / artwork defects etc.

Rgds / Charles.C

[D-D]

Having searched the forums, I thought I may as well add to this thread rather than start a new one with the same title.
I always struggle with the CCP decision tree, even more so trying to apply it for packaging. For example, you check a delivery for signs of pest activity:
Q1: Are control measures in place? A: Yes, Receiving checks and logs condition of vehicle and raw materials delivery.
Q2: Does the step eliminate/reduce the hazard? A: Yes, Receiver rejects anything looking contaminated. Q2 Yes = CCP.

Goods in checks are quite clearly not a CCP. The only way I have found around this is to score the risk assessment rather than just consider the significance and just say all low scoring hazards are covered by prerequisites (in which case by the way, for packaging manufacture I have no CCPs).

Am I missing something here...?

[Charles.C]

Having searched the forums, I thought I may as well add to this thread rather than start a new one with the same title.
I always struggle with the CCP decision tree, even more so trying to apply it for packaging. For example, you check a delivery for signs of pest activity:
Q1: Are control measures in place? A: Yes, Receiving checks and logs condition of vehicle and raw materials delivery.
Q2: Does the step eliminate/reduce the hazard? A: Yes, Receiver rejects anything looking contaminated. Q2 Yes = CCP.

Goods in checks are quite clearly not a CCP. The only way I have found around this is to score the risk assessment rather than just consider the significance and just say all low scoring hazards are covered by prerequisites (in which case by the way, for packaging manufacture I have no CCPs).

Am I missing something here...?

Dear D-D,

Yes, i think you are getting confused over prerequisites.

Maybe revisit yr previous thread -
http://www.ifsqn.com...dpost__p__48871

Another possible variation which (presumably deliberately) avoids some of the logic PRP conundrums would be to use a modified Codex Tree like the Campden 5-question version - this directly introduces the PRP option as the opening question. Seems well-accepted these days. You then have the choice of self-defining yr prerequisites a la PAS220, whatever.
 campden codex tree.png   143.13KB   36 downloads

IMO, it is not inconceivable that some people might regard goods-in checks as a CCP, this can simply be a question of methodology, although the current trend is to minimise the number of CCPs of course.... hence prerequisites

Rgds / Charles.C

[D-D]

Dear Charles,
If I can't even remember my own previous posts then you are right and I am getting very confused!
That was a year ago and now I am applying the same principles in a different area and for a different standard, which has provided "generic" plans for companies to modify and customize. The trouble I had was arriving at the CCPs the standard did as scoring out the Likelihood and Consequence as I described previously never took me into the range needed for decision tree treatment. I put this to them and was told that was fine. If our PRPs control what they called CCPs then it is okay as long as it is valid and defendable. So we have no CCPs!
I was thinking of inventing a new control called "KCP" = Key Control Point to highlight what the guidelines called CCPs (which I do agree with as being the most important controls). I could easily come up with a "KCP Control Chart and Master Plan" in the same way as for CCPs. Not sure though if that would be welcomed as a good idea and best practice or derided as corruption of the HACCP system and unnecessary! What do you think to that idea?
By the way, do you have a web link you could post please to the Campden information where they discuss that decision tree?
Thanks!

[Charles.C]

Dear D-D,

I suspect this is getting a bit OT but never mind.

I was thinking of inventing a new control called "KCP" = Key Control Point to highlight what the guidelines called CCPs (which I do agree with as being the most important controls). I could easily come up with a "KCP Control Chart and Master Plan" in the same way as for CCPs. Not sure though if that would be welcomed as a good idea and best practice or derided as corruption of the HACCP system and unnecessary! What do you think to that idea?

You will probably be regarded as a troublemaker unless you are already “Top Management” so what you say goes regardless. Especially if the MD has no idea what HACCP means.

The fact is that there are a miscellany of methodologies for doing HACCP. They are probably all debatable in some way or other and one often loses sight of what the basic concepts mean, let alone how to implement them. Plus companies may have fixed ideas of what works for them. I recall the old, engineer-beloved, anthem – "If it ain’t broken …."

IMHO it is necessary to convince oneself that the presented format makes (logical) haccp sense. If otherwise, some further thought/trepidations will probably be involved. Possible solutions on this forum will usually require details.

IMO, yr original query in this thread can be handled as a CCP or a PRP but most people these days seem to (similar to PAS220) (a) define incoming control as PRP, (b) score as non-significant. Nonetheless, it is not too difficult to find examples of haccp plans where incoming control is a CCP although mostly not from recent years perhaps. It may also depend on whether you must have at least one CCP ?

I used one element of incoming control as a CCP in my “model” yoghurt example here for iso22000, partly since it seemed to be an industry favorite in textbooks, ie validatable. I also tried to defend it in the context of iso22000 in the text notes. Needless to say it was challenged. Such is life, swings and roundabouts.

I think the clip originally came from Googling. Also see this thread –
http://www.ifsqn.com...dpost__p__55138

Rgds / Charles.C