I am preparing an HACCP plan/PRPs for our food contact packaging company. We use thermoforming molds to 'print' packages onto rolled sheets of various polymers. We label the finished product packaging boxes used for these containers for traceability/identification purposes, but we do not label individual packages..except for 2 customers.
Case 1: should we consider placing nutritional info labels on a client's food contact packaging product a CPP, because of the risk of allergens? Worst case scenario: Let's assume the customer has a cross contamination or modifies his recipe and for some reason the info does not reach us. We place the labels on the container and an undeclared allergen is found in the client's product which then leads to a recall. Since we put the label, would we be responsible for the recall?
IMO a CPP is required, I would have the customer verify and confirm the accuracy of the label at every order they make with us to ensure there is no mismatched information. I would like to add that the labels are printed by a third party (the customer sends the info to the label printer who then send them to us to affix on the packaging). Are we responsible for ensuring the accuracy of each of these labels? I assume yes but if someone could give me their thoughts on that I would greatly appreciate.
Case 2: We have a customer where we print the nutritional info labels and we affix the labels onto the food contact packaging, this customer places one order per year, so this type of production is not done on a regular basis in our plant. In this case, the label information is confirmed with the client before processing each order. Once again, are we be responsible if a food recall is required?
We have a label management system (SOP) appended to our prerequisite, and of course an allergen management program (in the PRP, and as an SOP). We do not process any food, and any food that enters the plant is restricted to the lunch room, and lunchroom garbage can. We do not have vending machines either.
These 2 cases seem a bit ambiguous to me, since they kind of seem like a CPP but a CPP we have once or twice per year..or not OUR CPP but theirs..
Sorry for the long post..
Thank you in advance for your help