11 replies to this topic

[Heidi_SQF]

Just curious....we work with thin-walled food contact packaging.  Both primary and secondary application.  We have reviewed our process and HACCP plan several times especially over the past couple years with switching from AIB to SQF.  We currently don't have any CCPs listed, but I am concerned that I am overlooking something in our process. 

 

Didn't know if anyone else had experience with HACCP in this specific industry.  Interested on hearing your thoughts.

[FurFarmandFork]

My plant manufactures PET and I haven't identified anything requiring a CCP at this time provided pre-requisites are maintained. The fact is that extrusion temperatures take care of microbial hazards, chemical hazards are monitored by maintaining a proven process and periodic monitoring, and physical hazards are addressed by maintenance and environment.

 

The more important piece is a real hazard analysis where you can demonstrate that if something were to happen that made your product dangerous, there are systems in place that would inform you of a problem other than customer complaints.

[Heidi_SQF]

FurFarmandFork

 

Thank you so much.  I am working on getting a list of hazard analysis and risk assessment items together for us to work on as a company over the 2nd half of the year.  This is much appreciated information.  I want to ensure that our program is not only solid now, but for years to come.

[ctzinck]

we are a flexible food packaging converter and we do not have CCP's either

[Robert Daigneault]

We have gone thru 3rd party reviews and customer audits and presented our HACCP plan without CCPs.  I guess the important thing is continually review the assumptions and steps and make sure nothing has change in raw materials or risk assessments.

[FoodSafetyNinja]

Just curious....we work with thin-walled food contact packaging.  Both primary and secondary application.  We have reviewed our process and HACCP plan several times especially over the past couple years with switching from AIB to SQF.  We currently don't have any CCPs listed, but I am concerned that I am overlooking something in our process. 

 

Didn't know if anyone else had experience with HACCP in this specific industry.  Interested on hearing your thoughts.

 

Hi Heidi

 

How about putting it through the BRC Packaging Version 5 criteria?

 

The hazard and risk analysis team shall identify and record all potential hazards that are reasonably expected to occur at each step in relation to the product and process. The hazards considered shall include, where relevant:

- microbiological

- foreign objects

- chemical contamination (e.g. taint, odor, allergen, component transfer from inks, varnishes and glues)

- potential problems arising from the use of recycled materials

- legality

- defects critical to consumer safety

- hazards that may have an impact on the functional integrity and performance of the final product in use

- potential for unintended migration of substances from the packaging material into food or other hygiene sensitive

product

- potential for malicious intervention.

 

I attach a template I used. 

 

After working with food only for the longest time, it was eye opener what to look for when approving packaging suppliers now. Hope it helps, also no CCP's identified this side.

Attached Files

•  Hazard Analysis.xlsx   78.07KB   348 downloads

[Charles.C]

Hi Heidi,

 

It obviously depends on yr specific process and the use of Prerequisites is occasionally subjective.

 

If you would like to see some perceived CCP possibilities for food packaging can try this site -

 

https://www.iopp.org...cfm?pageID=2267

[chichai]

Thank you so much FoodSafetyNinja! That's the file i needed!   

[Charles.C]

Hi Heidi

 

How about putting it through the BRC Packaging Version 5 criteria?

 

The hazard and risk analysis team shall identify and record all potential hazards that are reasonably expected to occur at each step in relation to the product and process. The hazards considered shall include, where relevant:

- microbiological

- foreign objects

- chemical contamination (e.g. taint, odor, allergen, component transfer from inks, varnishes and glues)

- potential problems arising from the use of recycled materials

- legality

- defects critical to consumer safety

- hazards that may have an impact on the functional integrity and performance of the final product in use

- potential for unintended migration of substances from the packaging material into food or other hygiene sensitive

product

- potential for malicious intervention.

 

I attach a template I used. 

 

After working with food only for the longest time, it was eye opener what to look for when approving packaging suppliers now. Hope it helps, also no CCP's identified this side.

 

Hi FSNinja,

 

Thks yr attachment.

 

I am not directly familiar with Packaging or the SANS FS Standard but i suspect it owes some of its content/structure to iso22000.

 

I much admire the effort/organisation  that went into yr (afaik) relatively novel PIGS/haccp presentation but I would make a few comments on the ultimate result as shown  -

 

(a) Mixes together Safety/non-safety evaluations. maybe this is Packaging / SANS-HACCP required but not a (currently) typical (food) haccp hazard analysis IMO.

 

(b) you have set the impact (severity) for every hazard at 1 (ie ~ negligible) !!! For example, incorrect printing as per customer specification. This is surely implausible..

 

(c) Your PRP of "Supplier Control" might be more appropriately designated as "Supplier Approval" IMO.

 

(d) Seems to me you you have defined some control measures only in a general way, eg specification management. I believe a control measure for a process step needs to be specific to the identified "hazard" unless it is being controlled by a PRP.

 

(e) The format does seem ultimately to generate a rather laborious (= 6pgs) methodology in comparison to a traditional 1 page hazard analysis ?.

 

Nonetheless, it's an impressive "work of art/science".

 

PS - Rightly or wrongly, IIRC (eg Post 7) some other haccp packaging plans do succeed in finding some CCPs. It's all subjective of course.

Edited by Charles.C, 29 June 2017 - 10:35 AM.
edited

[Robert Daigneault]

We had similar findings.  It was accepted by the 3rd party consultant performing our BRC PACK 5 Gap Analysis.  Keep in mind that that puts a high dependence on the Pre requisite programs.

[Heidi_SQF]

Hi Heidi

 

How about putting it through the BRC Packaging Version 5 criteria?

 

The hazard and risk analysis team shall identify and record all potential hazards that are reasonably expected to occur at each step in relation to the product and process. The hazards considered shall include, where relevant:

- microbiological

- foreign objects

- chemical contamination (e.g. taint, odor, allergen, component transfer from inks, varnishes and glues)

- potential problems arising from the use of recycled materials

- legality

- defects critical to consumer safety

- hazards that may have an impact on the functional integrity and performance of the final product in use

- potential for unintended migration of substances from the packaging material into food or other hygiene sensitive

product

- potential for malicious intervention.

 

I attach a template I used. 

 

After working with food only for the longest time, it was eye opener what to look for when approving packaging suppliers now. Hope it helps, also no CCP's identified this side.

FoodSafetyNinja,

 

This is a huge eye-opener for me as well!  Thank you!  I just wanted something a little more solid to go back to my HACCP team with to give them the confidence that we were moving in the right direction.  Your help is much appreciated!

[DN_QAMGR]

Hi Heidi, going for my 4th BRC Audit for Issue 5. 

 

We have not identified any CCPs in our process for blown film extrusion with PE. 

 

My main issue is Quality (meeting size, thickness, color, etc). I want to make a Quality CCP, but I'm nervous because its been difficult to maintain my BRC program with the staff. 

 

Seems like everyone responded with prerequisites and support to how to evaluate your HACCP. 

 

Just verify and validate your prerequisites and I'm confident that is good support for your HACCP plan. For BRC, if I'm unsure, I do a risk analysis and its supported my areas of concern. 

 

Hopefully I've added some help to this subject. 

 

Good luck.

 

DNQMGR