Dear mtmoore4,
I have studied the first uploaded materials.
Let me say first that I have no experience in packaging material HACCP plans. So my remarks are generally speaking with a food back ground and actually I just checked if I understand it and would approve it.
What I did not found in your HACCP Manual is the definitions/descriptions of occurrence and severity. On page 8 of 14 you describe that both can be low, medium or high. But you did not declare what low, medium and high is. For good understanding for external readers (e.g. auditors) and to help HACCP team to asses the hazards consistently, you should determine what you mean with low, medium and high. Give it a number! Is high occurrence monthly, weekly or daily? And low occurrence is this monthly, quarterly, annually or once in 5 years? It makes a lot of difference in your assessment. If possible and easier you can also use terms as once every order, once every 10,000 packs, etc. Just what fits your process and organization. The same for severity. Is low severity: receiving a complaint and high severity: people might die?
Then on page 9 of 14 hazard identification and assessment starts.
per ingredient/process step you identify the hazards. (again, with my background it is hard to see if you are missing relevant hazards)
for each hazards you than decide if the potential hazards is significant for food safety. This decision should be justified in the next column.
I think it is very strange that you decide for all identified hazards, that these are not including significant food safety risk. A few years ago there have been incidents with heavy metals from printing ink on the carton going through the plastic inner bag into the products. Please keep in mind that food products might be stored for years in your cartons.
As motivation for this NO-answer you gave N/A (not applicable). I expect a justification here related to the NO answer. WHY is the hazard identified not a relevant food safety hazard. It would be great if you can justify with scientifically literature, reports of authorities or practically experience.
Then, out of the blue, there is a decision if the hazard is a CCP or not. I expected to find per hazard an assessment with occurrence and severity. Just as you indicate on page 8 of 14. For each identified hazard I expect the estimated occurrence (low, medium, high), the motivation for this (on with ground do you think the occurrence is low, medium or high), the estimated severity (low, medium, high) and the motivation for that (on which ground did you decide the severity is low, medium or high). The occurrence X severity leads to a risk and the risk leads to the conclusion CCP or not. I would like to see this all in a HACCP study. As reader (auditor) I would like to follow and understand your thoughts and motivations during your HACCP study. Therefore it should al be documented. Also for your own purpose. If you are to review after a year, you will find that, if you did not proper document this, you can not tell anymore why a hazard had a medium severity, etc. Especially if some members of the team has changed. This is my experience as HACCP team leader.
Missing hazards in your hazard identification:
- on page 5 of 14 at food safety characteristics you state that printing and labeling is very important to prevent allergen or legality non-conformities at your customers. This is not included in your hazard identification. Also not the hazard of mixing up different sleeves/printed packaging materials. This is something I frequently hear in food companies. (I just do not understand how this can happen) (within a stack of labels/sleeves some other labels/sleeves are found)
- the hazards you name on page 6 of 14 (general factory wide contamination risks) are not found in the hazard identification and risk assessment tables.
- Also on page 7 of 14 you name hazards that are not found in the hazard identification and risk assessment tables.