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#1 leila19

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Posted 22 July 2019 - 11:24 AM

Hi,

i work in gable top packaging manufacturer and i want to implant the HACCP system. i'm trying to make CCP for printing step.

We use double side PE paper board good quality. We have flexo machine and we use solvent based ink with wax. the reel is carried using the forklift to the machine from the storage area. The printed reel is manually is deposited on the floor after been wraped with the shrink wrap.

Can you help me to find ccp for the process.



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#2 Charles.C

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Posted 22 July 2019 - 05:00 PM

Hi,

i work in gable top packaging manufacturer and i want to implant the HACCP system. i'm trying to make CCP for printing step.

We use double side PE paper board good quality. We have flexo machine and we use solvent based ink with wax. the reel is carried using the forklift to the machine from the storage area. The printed reel is manually is deposited on the floor after been wraped with the shrink wrap.

Can you help me to find ccp for the process.

 

Hi leila,

 

Not my area but (maybe) some possibilities here -

 

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


Kind Regards,

 

Charles.C


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#3 lakmal

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Posted 25 July 2019 - 12:14 AM

Hi,

 

We are a manufacturer of flexible packaging for food contact and non-food contact applications. We also use flexographic printing process to print on plastic films ( PE, PP, PET, Nylon etc). After drawing up the process flow chart, HACCP Analysis and HACCP Plan for printing, we identified "Residual Solvents" in the printed film that can taint the food products as the only CCP for the printing process. All other parameters are controlled by QCP's, OPRP's, PRP's etc. We check the residual solvent levels through Gas Chromatography but only for food contact or hygiene sensitive ( eg surgical sponges) applications. Hope this is of help.

 

Kind Regards

 

Lakmal



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#4 Hoosiersmoker

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Posted 25 July 2019 - 01:02 PM

We are also a flexible, food contact packaging packaging manufacturer from paper roll stock through packaged finished product and we use both Litho and Flexo in our process.

 

Once we completed all of our PRPs, we found no CCPs throughout our entire process. All auditors have echoed that they have not expected to see any CCPs for us.

 

We stage all of our rolls on the floor but we discard the first 4 or 5 wraps and during the die-cut process the edges are also removed and scrapped eliminating the risk of contamination.

 

We store all rolls on edge and the bottom roll is in direct contact with the floor. We've never gotten a non-conformance.

 

If you've identified a potential hazard, maybe it can be addressed by a PRP or other procedural control? Then perform your Hazard Analysis again after you've implemented another control measure. We did everything we could to engineer the risks out before we performed Hazard Analysis. Low / no hazard = no CCP



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#5 leila19

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Posted 30 July 2019 - 06:36 AM

Hello,

Now, for the quality assurance, how to define the frequency of the microbiological checks (testing surface) that we should provide for the rollers of the flexo as they are in contact with board during the running knowing that many auditors asking that.

 

Thanks



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#6 Hoosiersmoker

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Posted 30 July 2019 - 11:05 AM

Is your product food contact? Ours is and we were still able to gain exemption from Environmental Monitoring by demonstrating that our program's effectiveness and historical lack of issues, reduced the risk low enough to determine the swabbing unnecessary.

 

We did swab in order to prove this but found no presence of pathogens or other biologicals/contaminants (other than on outer packaging) proving our cleaning program and building condition either eliminated or prevented their introduction to the process. That along with an annual review of our Environmental Risk Analysis, to review anything that might have changed, were enough evidence for our CB to grant the exemption.

 

Again, remembering we are a packaging manufacturer, there is no introduction of contaminants from our raw materials or residual contaminants from our machines, that along with our GMPs reduce the risk of introduction from employees. I would perform a thorough Risk Analysis to determine the potential sources and see if your PRPs and GMPs do the same for your facility.

 

Hope this is helpful.



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#7 mbadila

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Posted 30 July 2019 - 05:39 PM

Is your product food contact? Ours is and we were still able to gain exemption from Environmental Monitoring by demonstrating that our program's effectiveness and historical lack of issues, reduced the risk low enough to determine the swabbing unnecessary. We did swab in order to prove this but found no presence of pathogens or other biologicals/contaminants (other than on outer packaging) proving our cleaning program and building condition either eliminated or prevented their introduction to the process. That along with an annual review of our Environmental Risk Analysis, to review anything that might have changed, were enough evidence for our CB to grant the exemption. Again, remembering we are a packaging manufacturer, there is no introduction of contaminants from our raw materials or residual contaminants from our machines, that along with our GMPs reduce the risk of introduction from employees. I would perform a thorough Risk Analysis to determine the potential sources and see if your PRPs and GMPs do the same for your facility. Hope this is helpful.

 

I also work in manufacture of food packaging and found this to be very interesting.  Having previous experience in food plants, I have seen how Environmental Monitoring can be an expensive and time consuming program.

I'd like to ask about the research you used to apply for your exemption.  Did you have any sources of academic studies that looked at the industry as a whole, or were you able to get the exemption with only your companies history? 

Also, if you don't mind me asking, how many years have you been certified?  This may be straying from the topic slightly, so if you'd like to talk more via PM I'd be very thankful.

 

Thank you,

 

    MBadila



#8 lakmal

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Posted 31 July 2019 - 09:53 PM

Hi Leila19,

 

Our operations involve extrusion of PE films, printing, laminating, microperforating, slitting and pouch making.

 

We obtained accreditation to BRC Packaging in 2013 with Grade A and maintained Grade A until 2016 and then achieved Grade AA in 2017, 2018 and 2019.

 

We have been doing environmental microbiological testing since 2013 only annually and the Auditors have been happy with our approach. I know it is an expense but I would not call it too expensive. We check surfaces like lay on rollers closest to the winders, conveyor on the pouch machine for Enterobacteriaceae and keep exposure plates for Yeast & Mould close to these locations.

 

Other peoples comments that they have validated that there is very low risk in the packaging industry requiring swabbing are correct as it is unlikely the organisms will survive in such inert and dry substrates. We have never found results of any significant presence of these organisms.

 

However, what you need to be concerned if at all is the Yeast and Mould as any damp conditions such as a leaking roof can harbour Yeast & Mould.

 

Regards

 

Lakmal



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#9 Charles.C

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Posted 01 August 2019 - 03:50 AM

Interesting discussion (maybe occasionally a little OT) however related FS Standards are nowhere mentioned. Regardless of GFSI et al,  I suspect some auditors will "expect"  "X", others "Y".

 

If you look back to say, BRC, one decade ago I think APC + Y&M was a typical, recommended, maximal, Packaging EMP. Now, based on current threads, the situation  seems to have become  "confused". A workload/ financially sensitive decision is whether monitoring pathogens like Salmonella and L.mono or indicators like E.coli/Enterobacteriaceae is necessary. "Risk-based" opinion in this thread seems =  Not.

 

I suggest a fuller BCP response to OP might, (as usual), have been  assisted by a flowchart (HACCP 101, eg Post3) + FS Standard (if any).


Kind Regards,

 

Charles.C


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#10 leila19

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Posted 03 August 2019 - 06:20 AM

Hello,

As you, what i think that it is difficult to microorganism to survive in such dry conditions. However it's more safe to not neglect this fact. So in this case, how to define the frequency of the swabbing that normally should be done.I want also to khnow about the methods and the product that you use to clean the flexo machine khnowing that it should be safe because with hot temperature it's risky to use flammable product.

For us, i'm providing a product based on ethanol and isopropyl that should be pulverised in all the contact area for 5 min for the die cutting and sealing machines .Should i use the same for the flexo to clean the cylinders.

Also as a quality control, what are the parameters that i should control in the printing process.

 

Best regards


Edited by leila19, 03 August 2019 - 06:21 AM.


#11 lakmal

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Posted 04 August 2019 - 11:26 PM

Hi,

We do the Environmental Microbiological testing annually. It will be necessary to consider testing as per Clause 4.8.5 in the new BRC Packaging Standard - Issue 6.

 

We clean our rollers etc with common solvent ( in our case 80% n-Propyl Alcohol & 20%  n-Propyl Acetate).

 

We check the following parameters during the printing process - substrate used for printing ( type,colour, size and gauge), corona treatment on the film, whether printed on the correct side of the film, Ink adhesion with 3M Scotch 600 tape test, print type to the standard/ approved artwork, registration of colours, print colours with PMS colour book and X-Rite spectrodensitometer, repeat length of print, image width, number of prints around the cylinder, number of prints across the cylinder, eye spot size, colour and position, bar code number, colour and scanning grade and most importantly the residual solvents with Gas Chromatography for food contact and hygiene sensitive materials.

 

Best regards

 

Lakmal



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#12 leila19

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Posted 06 August 2019 - 10:35 AM

Hi, 

Can you please explain what do you mean by gauge ?

 

Thanks;



#13 lakmal

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Posted 06 August 2019 - 09:31 PM

Hi,

 

Thickness is also known as "Gauge" in the plastics industry.

 

Regards

 

Lakmal



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#14 leila19

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Posted 14 August 2019 - 12:47 PM

Hello,

The meaniong of the eye spot size please ?

 

Thanks



#15 lakmal

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Posted 16 August 2019 - 02:14 AM

Hi Leila,

 

Eye spot or the eye mark on a printed film is normally a rectangular solid print which is printed with a solid dark colour along an edge of the film at a regular interval ( ie at the repeat length of the print).  Electronic eye in the packaging machinery fires each time it detects the eye mark and controls each cycle of packing. This is an explanation in the most basic terms.

 

Please refer to the attached photo. Eyemark is the black rectangle.

 

Regards

 

Lakmal

 

                                                                                      



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#16 lakmal

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Posted 16 August 2019 - 02:32 AM

Hi Leila,

 

My apologies. The photo did not upload properly. Now attached.

 

Regards

 

Lakmal

Attached Files



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#17 Hoosiersmoker

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Posted 16 August 2019 - 01:07 PM

I also work in manufacture of food packaging and found this to be very interesting.  Having previous experience in food plants, I have seen how Environmental Monitoring can be an expensive and time consuming program.

I'd like to ask about the research you used to apply for your exemption.  Did you have any sources of academic studies that looked at the industry as a whole, or were you able to get the exemption with only your companies history? 

Also, if you don't mind me asking, how many years have you been certified?  This may be straying from the topic slightly, so if you'd like to talk more via PM I'd be very thankful.

 

Thank you,

 

    MBadila

My apologies MBadila, I thought I had already responded to your request

I cited the following as the academic study: "published studies indicate that even though there may be a minor presence of cytotoxins in some paper products they do not pose a health hazard. (Reference: Health safety of food contact paper evaluated by in vitro toxicological methods. Adam Vavrouš, Marketa Dvorakova, Kristina Kejlova, Dagmar Jírová September 2015). Even Bacillus related to paper products, mentioned in 2.4.8.3, has very low risk of causing illness. It is in fact present in most human digestive tracts naturally and does not typically survive paper making processes."

Background: In SQF Ed 8.1, 2.4.8 Environmental Monitoring is NOT a mandatory element although proof is obviously necessary. 2.4.8.3 specifically states Bacillus ssp as being an inherent risk in paperboard. The above refutes that claim as unfounded. I think that is the first step, then your PRPs and GMPs control the potential for introduction of contaminants. We swabbed contact and incidental surfaces, and surfaces removed from production to demonstrate the lack of environmental contaminants inherent to the facility and incoming materials. The only contaminants we found were on the outer packaging of our paperboard roll stock and those were extremely low and are discarded before the rolls are loaded into the machines. Risk analysis showed only very low risk throughout every process.

 

Hope this helps



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#18 leila19

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Posted 19 August 2019 - 07:48 AM

Hi,

I want to thank you for the explanations.

It was really helpful.

 

 Best regards



#19 leila19

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Posted 19 August 2019 - 11:07 AM

Hi,

i'm preparing now a file refering to the food contact certificate. they are requesting the followings papers:

-List of raw material and substances (board, ink, varnish, the solvents..)

-Food contact certificate for all above raw material and substances from the supplier.

 

For me the problem, is that for the solvents no opportunity to get the certificate from the supplier because the alcohol(isopropyl alcohol), the acetate, the methoxy propanol are normally not alimentary.

So can someone guide what to do

 

Thanks.


Edited by leila19, 19 August 2019 - 11:07 AM.


#20 hoangvu1511

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Posted 19 August 2019 - 02:21 PM

i consider cost when sending sample for testing external.






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