Dear Sharon / E-B,
At least I now know what IML is. Thank you.
And further thanks to Sharon for the interesting comments.
But regarding CCP/OPRP, i have to maintain my original opinion inasmuch as i deduce we are still talking about external inputs to the actual manufacturing process. On the other hand, if the labels are part of the total manufacturing process as being analysed, my opinions might change. Unfortunately no flowchart is presented by OP.
It sounds like Sharon utilised a different decision procedure as compared to use of PASS220 / ISO 22002-1?. One outcome of such approaches can sometimes be an abundancy of OPRPs (and work?). Ironically, such an aspect was a well-known (CCP) criticism of early HACCP methodologies (which also struggled regarding the allocation between PRPs and CCPs). I previously met a similar (input) conundrum in the detailed hazard analysis for yoghurt manufacture (available on this forum) and partially resisted the PAS220 format (my logic is presented at the relevant yoghurt posts here). However, after further experiences, I would probably now choose to revise that evaluation into all PRPs as per PAS220.
Nonetheless, my opinion is undeniably arguable since the IFSQN package available on this site has a detailed menu of OPRPs after utilising a slightly different (I think) interpretation of the standard.
Would be interesting to get more poster comments but I suspect use of this ISO standard for packaging is, overall, rare.
Rgds / Charles.C
PS i presume that E-B is familiar with the (IT-published) detailed, model hazard -CCP analysis (using traditional HACCP) for rigid plastic packaging whch is linked in a current parallel thread here.?