Is cross contamination impossible in packaging?
Hi Everyone!
So long since the last time I visited IFSQN. BTW I have a question. It started with a conversation with my Superior. According to my superior, it is impossible to have a cross contamination in our Plant since our products are just labels, cartons and stickers and not food. Is that right? Can anyone enlighten me?
Many thanks!
However, in labelling you may consider cross contamination as contaminating one order with another and getting mixed labels.
How do you prevent this through, product identification, segregation and line clearance etc.?
Simon
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We have sorting area where our products such as labels and stickers are sorted. Non conforming products are taken out also during the sorting to prevent it from being delivered to the customer.
How about if dirty equipment or PPE is carried in the sorting area, will our products be cross contaminated?
The existence and survival of microbes on packaging is very low. Of course if factory, equipment, materials, personnel are unclean and unhygienic then it could be possible, so good standards are very important. To check this you should have an environmental monitoring program in place including settle plates to check air for yeasts, moulds and TVC and also swabbing of product contact surfaces and hands, perhaps even product itself.
Of course if factory, equipment, materials, personnel are unclean and unhygienic then it could be possible, so good standards are very important. To check this you should have an environmental monitoring program in place including settle plates to check air for yeasts, moulds and TVC and also swabbing of product contact surfaces and hands, perhaps even product itself.
Hi Simon,
I agree with you Simon. Our current condition is that we don't have washing area prior to production and our Comfort rooms are exposed in the production in such a way that its windows are directly open to the prod area. The CR for production workers is also located at the entrance area of production. We only issue one hairnet and one face mask to every employee. Many of them dont wear their Face mask and their hairnets are not arrayed properly in a way that some of the workers hair are exposed. We also don't have control over the disposable PPE. That is why I think our product could be contaminated anytime.
You don't have control over dirty PPE??? Can you explain further
It sounds like you may have a general filth problem in which case, yes you could contaminate the packaging, and no one wants a hair stuck to the side of a roll of labels when they open the carton
Are the employees trained on GMP's?
Hi Scampi,
Yeah. That's right. We issue disposable hairnets and face masks to our visitors and clients but after that I dont know where those things go. There's no one assigned to collect and dispose them. We don't have area where we could segregate dirty and clean PPE's. We don't even have a procedure on that.
We have GMP. Actually, our QA Manager conducted a GMP re orientation last tuesday But as for the training, I dont know if they had. I don't know if our employees have absorbed what's given to them. Is it necessary to conduct an assessment right after the re-orientation? Thanks!
Hi Donie,
It sounds like yr initial problem is implementation of GMP with respect to Environment, Personnel/Management. Next comes the Process. :smile:
Are you certified to BRC/IOP ?
Hi Charles,
Yes, that's right!
Well, not yet. We are still halfway with our preparation for BRC/IOP. Hopefully we could finish it next month.
Ok, to become BRC certified you're going to want to nail down implementation like Charles mentioned
You need waste collection SOP---who, how often etc
You'll probably also want a daily GMP check of some sort to verify daily that the basic GMPs are being followed...hand washing, no gum/candy waste where it belongs those sorts of things
It's all fine to have a program written, but if you're not doing what you say you'll do, you won't get the certification you seek
What sort of orientation did the QA manager provide without programs to follow?
Hi Scampi,
That's what I want to do now. We have waste collection which is done by our Maintenance Department but the procedure isn't established yet. Our team will keep an eye on that.
Actually we have GMP audit conducted every month but I think we should improve it, get more strict in implementing it, and add daily GMP Check as well.
We already made some procedures, policies, work Instruction etc. which is based on the practices we do in the plant. But It'll just take some time to practice some revisions we've made.
We conduct GMP re orientation once every 4 months but there's no changes because there's no program to enforce it. What programs should we implemment to make the orientation effective?
Scampi,
The issue with paper and board packaging lies within the scope of food packaging with direct food contact.
Although it not cross contamination in the classic sense of the term but any direct food contact with paper and board is subject to the risks of microbial and chemical migration from the paper or board. Most paper is now very high in recycled content and this is where the risk resides.
There is also the possibility of chemical compound migration from the inks used.
Hope this helps,
Tamale
Hello Donie,
What is your product? We have suppliers of packaging here in Philippines but not all certified. Maybe your company is the one we are looking for....
regards,
redfox
Hi Redfox,
We manufacture labels, stickers, and Corrugated cartons. We are not yet certified but our Major Clients conducts Annual Audit on our Plant Sites and we always pass the Audit. May I know what are your products too?
Regards,
Donie
As a label producer, I can tell you that in our field cross contamination is considered putting multiple items on one skid, or splicing different labels together. Line Clearance is your CCP for cross contamination.
As a label producer, I can tell you that in our field cross contamination is considered putting multiple items on one skid, or splicing different labels together. Line Clearance is your CCP for cross contamination.
Hi djammur,
Also see Post 12 of current thread and this parallel SQF thread -