7 replies to this topic

[gary]

Hi Simon,

Excellent website. I am sure I will use it regularly.
I attended the PIRA seminar and found it very useful. My company is in the process of attaining BRC/IOP Standard accreditation and as we have just started I picked up a lot of useful info. We currently manufacture components predominately for the Spirits industry and, due possibly to the products being packaged, we have not had the same pressure applied as food manufacturers have regarding the standard. However there has been a significant change in our customers attitude over the last year or so and we are now being asked about accreditation to the standard as our customers, quite correctly, see this as a fundamental requirement.
We are going down the HACCP route but I was interested to find out that some of the presenters did not advocate this as a necessity. Some said that Risk Assessment would suffice. Personally speaking I took them to be the same. What difference do you see is there between them?

[Simon]

Hi Gary,

Thanks for joining the forum and for your kind comments.

At the Pira Seminar various presenters spoke about the healthy debates that ensued during the formulation of the standard and I am sure that the HACCP debate will have been one of the most vociferous.

Because of it's negative history in the packaging industry, I'm sure the team believed that the term 'HACCP' would frighten us packaging people off. The actual requirement of the standard is for a "Hazard Analysis".

In answer to your question I don't know what the difference is - they both evaluate risk.

The thing is HACCP or a Hazard Analysis based as much on the principles of HACCP as possible, can provide an extremely useful step-by-step plan for guiding you through the process of identifying hazards in a food packaging context. There is a HACCP study guide here: http://www.saferpak.com/haccp.htm

You may not use or follow all of the requirements of HACCP, but as long as you identify and control the hazards and meet the requirements of the standard it doesn't matter. HACCP just provides some structure to the project.

Rather than making it nice and vague, I don't know why they didn't just specify HACCP it would have been more helpful and the standard does infer its use.

I am here to be shot down though, and if anybody has used a different method please share it.


Kind Regards,
Simon

[mikelond]

Just to add my 'two-penneth-worth', as we say oop north, the distinction between HACCP and Risk Analysis was brought home to me during a recent customer audit last week.
We produce flexible packaging, predominantly for the food industry, and as such, largely by default, had adopted the HACCP system.
However, during the audit, the system was reviewed by the auditor, and the following observation was made.

As he was from one of our food contact suppliers, and very clued up about BRC/IOP, he pointed out that while we had covered all the critical control points with regard to HACCP, it still missed some critical control points.

The example he gave was this......................

Supposing we had a design to print for this customer, where an ingredient for the product was peanuts. The packaging we were supplying was the overwrap for four tins of the product, so we were not even supplying direct food contact material in this instance.

During the proofing and printing of the packaging, it was not noticed that the statement alerting the consumer to the presence of nuts in the product was omitted from the outer packaging, resulting in the product being bought and consumed by someone with a nut allergy. This is a critical control point directly related to product and end-user safety, but was not covered by the HACCP system.

The point I'm getting to is that the HACCP system is fine for identifying the direct physical risks, but can cause a certain amount of 'blinkering' to the wider risk implications not directly related to contamination or defect.
As we speak, I am busy taking apart our current system to encompass such issues, which will then become a Risk Assessment Analysis, rather than a HACCP system.

[Simon]

How's thee diddlin? as we say oop north! :P

Thanks Mike you raise an excellent point on an important subject.

Although we have spent a lot of time on the forum talking about physical, chemical and microbiological risk we have neglected an important requirement of The BRC/IoP Packaging Standard, that is to include 'packaging defects critical to consumer safety' in the hazard and risk management system (3.1.1).

I must admit when the standard was first published way back in 2001 we looked at this requirement and were a little confused. However, when we looked at our HACCP system we realised that the only CCP we had identified at the time was in fact a 'defect' as above. We had wrongly pigeonholed it as a 'physical', but the important thing was that we had it covered. To add to your wrong ingredient printing example here is another:

The process was pre-cut lidding for dairy, food etc. Basically reels of heat-seal lacquered foil printed, punched out into individual lids and supplied to customers 1,500 lids per sleeve 36,000 in an outer for sealing their products.

With thousands of live designs and dozens of punching machines there was a real risk of mixing a few lids of one design with another and it did happen from time to time. Believe me when it happened the proverbial 'hit the fan', the retailers and our customers the packer/fillers took this kind of complaint extremely seriously not least because it presented significant health risks to the consumer.

We controlled the hazard by implementing a range of measures including a strict one design per packing table rule and a pre-order clean down (verified by a supervisor) of machine, table, which even included emptying the bin. It took a while to become ingrained but eventually worked.

The BRC/IoP Packaging Standard is not prescriptive in how you carry out the risk assessment / hazard analysis and as such you can use or bastardise any system you want if it works for you. I advocate the HACCP system because it provides a great framework for working through the hazard analysis and because of this you end up with comprehensive and logical documentation.

In this HACCP plan we simply added a 'D' for 'packaging defects critical to consumer safety' to the 'hazard types' column and we now have P, C, M, D (physical, chemical, microbiological and packaging defects).

It's an interesting subject area. We all know a fair bit about the generic contaminants but I think it would be very useful to hear accounts of other's specific 'packaging defects critical to consumer safety'.

Please let us know if you have identified any...

Regards,
Simon

[horsenailbucket]

I prefer to keep the issues separate else you can get too complicated, especially when trying to explain or train the technique. I would suggest that you use the haccp technique for the standard PCM hazards principles but also apply the same technique in a Quality CCP style - QCCP where instead of food safety hazard you identify quality consideration as your risk. In the labelling example, the quality consideration is 'incomplete labelling', the effect would be a customer complaint. The QCCP would therefore be adherence to a qc step during the component approval process.

I really like haccp as it is structured, so applying it to a quality plan works really well.

[Simon]

Hello Horsenailbucket,

A very unusual and interesting name - is it French?

In a Food Packaging context it's often the 'Quality' or 'Defects Critical to Consumer Safety' that present the highest risk to the consumer. In the nut labelling example if a set of unbelievably, unfortunate circumstances prevailed it could in fact be a death we were dealing with rather than a customer complaint for a quality problem.

I can't think of any other PCM food safety hazards that could cause a death in food packaging manufacture. It's for this reason and the fact that they can be significant food safety hazards that I'm keeping my Q's or D's slap-bang in the middle of my HACCP plan.

Regards,
Simon

[horsenailbucket]

Yes of course, but the point I am making is that there is a lot of overlap between food safety and quality, and environment, and health and safety. You could consider labelling as a pre-requisite to a haccp process because an operator is not going to be able to influence it directly.

On a similar matter I quite often do SHE audits - safety/hygiene/environment - due to this overlap. A clean plant with good waste segregation is likely to be food safe, environmentally friendly, not injuring the workforce, producing quality output and giving good yield (20% of downtime is directly caused by poor hygiene).

The name? The original title for Monty Pythons Flying Circus!

Cheers, Mike

[Simon]

Agreed there is definitely overlap and it's inefficient, but often promoted by systems developers - they teach people to think and work compartmentally. I'm all for integrated management systems!

I know one organisation that uses different coloured text within their procedures to highlight the key points of each of the disciplines:

H & S - Red
Environmental - Green
Hygiene - Blue
Quality - Brown
Rest - Black

Very ingenious but useless for the colour blind...

Anyway welcome to the forum Mr Horsenailbucket. Monty Python was truly fantastic - it reminds me of my youth. :D

Cheers for that Mike.

Regards,
Simon