12 replies to this topic

[ISOKirst]

Client is a label printer.

Currently have not identified mixed labels as a CCP.

Have had a rising number of incidents of this nature in last 18 months and wondering if this should be identified as a CCP.

Anyone else's experience or advice would be appreciated.

K

[Charles.C]

Client is a label printer.

Currently have not identified mixed labels as a CCP.

Have had a rising number of incidents of this nature in last 18 months and wondering if this should be identified as a CCP.

Anyone else's experience or advice would be appreciated.

K

Dear ISOKirst,

Not quite sure whether you are the receiver / user of the (mixed) labels. Or are you querying from the printer's POV ?

I hv assumed the former since not posted in a packaging forum.

Added later-(Wrong guess, see PS at bottom)

may depend on the actual error (eg see below)
may depend on a particular certified standard if relevant.
may depend on the product / process / consumer involved.

IMO - If the (correct) printing on the labels is controlling an allergenic hazard, may be a CCP failure. Some people might also regard it as a prerequisite failure (eg control of incoming ingredients / packaging) although repetitive failures could "lift" the status. IMEX a large rejected lot usually has quite a rapid curative effect.

If consequence is non-safety related likely to be a prerequisite failure at the most. could be argued as unrelated to the FSMS system.

Rgds / Charles.C

PS @ ISOKirst, after reading yr other post, i guess i guessed wrong. no problem.

Packaging not my field but from memory of label printing - haccp plans posted here, there is typically a (plate?) checking point prior to starting the run. This is a potential CCP from memory. suggest you do a little searching within the packaging forum.

Edited by Charles.C, 01 March 2013 - 05:47 AM.

[williamw]

How would you define your critical limit and monitoring for a CCP? I think if you treat as a CCP you may have issues.

We had an issue with this, primarily with mixed bundles in a box. We required all of our label vendors to package labels in trays with clear wrap and only one layer. This allows for the machine operators to quickly scan the label packages at the line a see if there is a mixed bundle.

Depending upon the system an option I have used in the past is to print labels so that when they are stacked there is a colored bar running down the edge of the bundle. Each label is printed so that the color and or position of the bar is never the same, thus the label machine operator can scan the edge of a bundle and assure that the bar is the same. This actually has an advantage over the tray system as it would identify a few labels mixed in a bundle.

The closest to a fail safe solution is a scannable code on the labels and an electronic scanning system. There was a recent article in one of the trade magazines about this type of system in use at, I believe, at a Hershey plant. If can find the article again I will provide a link. Of course this solution requires a significant investment that may not be justified by the risk if other controls are in place.

Finally, the place to start is to look at the control systems at your supplier. Since we went to the tray pack and required our label suppliers to add controls on their system we have not had an issue.

Personally I think we often get too wrapped up in is it a CCP or a prerequisite or something else. Frankly to me the question should be "do I have adequate controls in place to appropriately manage the risk." After that it becomes a semantics game that we can spend way to much energy trying to deal with.

Edit
Sorry missed that this would at the label printer same principles apply I think

Edited by williamw, 28 February 2013 - 05:12 PM.

[Simon]

Client is a label printer.

Currently have not identified mixed labels as a CCP.

Have had a rising number of incidents of this nature in last 18 months and wondering if this should be identified as a CCP.

Anyone else's experience or advice would be appreciated.

K

Yes of course you should. Call it what you want but you need some robust control measures in place in the area of line clearance between jobs, segregation, identification and traceability to prevent mix up's. It is possible, but requires a lot of effort and focus.

No time to expand right now as my laptop has died and I'm migrating to a new one

Regards,

Simon

[Peter Snopko]

I would suggest that this issue is a CCP, especially where there is allergen information printed on the packaging.items.

Also have a look at their PrePress process too to ensure that the original artwork has not lost any information when the printing plates have been made and are mounted on the press. Gang run jobs are always a risk when it comes to mixing printing plates. The Pre-Press area could also have a natural CCP.


Checkout the packaging manufacture HACCP models on the IOPP / FSAP web site. They have some good guidance on how to view this issue. http://www.iopp.org/...cfm?pageid=2264

Cheers
Peter

[Foodworker]

Mixed labels have the potential to kill, therefore severity is high.

You have had several instances in 18 months, therefore likelihood is high.

Difficult to see how this is anything other than a CCP.

The main consideration is where and what the Critical Control Point is. You need to identify how and where the mixes are occurring.

Are the labels on reels or sheets. If reels do you have in line camera systems, the correct operation of these could be your CCP.

Absolute line clearance procedures and records could be your CCP if there are no cameras.

Also look at any sorting operations if you have them.

[Mmmm_food]

In our production facility, using the correct labels is a CCP not just for allergens but also for diet products. Most of our products are very sugary so if one was mistakenly labelled with a diet label and consumed by someone with diabetes, the consequence could be fatal. I would expect this type of scenario to be considered in our label suppliers HACCP plan also.

[Charles.C]

In our production facility, using the correct labels is a CCP not just for allergens but also for diet products. Most of our products are very sugary so if one was mistakenly labelled with a diet label and consumed by someone with diabetes, the consequence could be fatal. I would expect this type of scenario to be considered in our label suppliers HACCP plan also.

Dear Chobbsy,

If i understand correctly, you are suggesting that for a diabetic to eat "very sugary" food represents a significant hazard, ie of potential fatality.

Can you validate this comment ?.

AFAIK, there are no statutory requirements anywhere regarding labelling warning concerning specific high limits of sugar content (but see below) ?
(I saw no mention of this aspect included in haccp plans available from link in post 5.)

Not saying your opinion is incorrect, just interested. i noticed this, apparently innovatory, link from mid 2012 -

http://www.nutrition...arnings-3-10233

Rgds / Charles.C

[Mmmm_food]

Dear Chobbsy,

If i understand correctly, you are suggesting that for a diabetic to eat "very sugary" food represents a significant hazard, ie of potential fatality.

Can you validate this comment ?.

AFAIK, there are no statutory requirements anywhere regarding labelling warning concerning specific high limits of sugar content (but see below) ?
(I saw no mention of this aspect included in haccp plans available from link in post 5.)

Not saying your opinion is incorrect, just interested. i noticed this, apparently innovatory, link from mid 2012 -

http://www.nutrition...arnings-3-10233

Rgds / Charles.C

Hi Charles

I have actually only been with this company for a relatively short time and the hazard analysis was already in place classifying the label as a CCP due to potential fatality if consumed by a diabetic. I had not thought to question it but now after doing some brief research I could not find much to support it.

The product is a known high sugar product so statutury requirements for labelling are not really relevant. The severity though could certainly be reviewed and possibly downgraded.

Thanks for making me think about it Charles.

[Gita]

hi,

We are a label and folding cartons producer. it is imperative that a hazard and risk assessment be done on the processes . However a risk also need to be done of the different defects / defective products , and its impact on your consumer. Mixed labels is a high risk, and definitely should be identified as a CCP. The necessary control measures must be put into place to contain risk.

[Foodworker]

Remember that labels may be printed for other sectors apart from food , eg medicines, cosmetics, toiletries and a whole range of other industrial applications.

The consequences of mixing up medicine labels can easily be fatal.

[Keith Ogden]

Hi, this is my first post after being a member for some time. I have been working as a Hygiene/HACCP/Food Safety consulatant, trainer and auditor in the packaging industry for the last 22 years.

Mixed label (or any mixed printed product) could definitiely be a hazard with varying degree of consequence - the most severe being death (with allergens such as peanuts, and if a sugar containing product is packed or labelled in a pack that states it is sugar free - e.g normal cola in a cola-light can).

The mixing of labels/printed packs or containers is a hazard - but you have to identify the particular process point or operation to identify the exact CCP. This could be, as previously stated, effective line clearance, effective segregation of finished product, effective operation of a bar code verifier, effective operation of a label verifying camera, effective/correct labelling of finished product (packaging), proper separation of gang printed/composite printed cartons/labels/reels, etc.

A camera system can only be designated as a CCP if it considered 100% effective in removing the hazard, i.e. identifying and rejecting any label or product different from that being printed in the current run - many camera systems are not capable of 100% effectiveness due to the close similarity of many printed designs, and the need for the camera to be in a "learning" mode at the beginning of the run. This therefore puts the CCP emphasis back to effective line clearance between different runs.

Control of mixed labels/printed product has resulted in the designation of CCP's at different parts of the process/operation in many parts of the food packaging sector including label printers, flexible packaging printers/converters, folding cartons, beverage cans, etc.

Hope this helps.

[cazyncymru]

Hi Charles

I have actually only been with this company for a relatively short time and the hazard analysis was already in place classifying the label as a CCP due to potential fatality if consumed by a diabetic. I had not thought to question it but now after doing some brief research I could not find much to support it.

The product is a known high sugar product so statutury requirements for labelling are not really relevant. The severity though could certainly be reviewed and possibly downgraded.

Thanks for making me think about it Charles.

As a diabetic, i don't look at the labelling to see if something is "highly sugared", and if i did, and it was, it wouldn't stop me eating it. To be honest, i tend to avoid foods that are either specifically made for diabetics, or contain artificial sweetners as i tend to have more trouble with those.

I'm in agreement with Charles on this

Caz x