BRC 2.2.6: HARA Assessing New Hazards - plastic caps, injection moulding
I am struggling to add this new HACCP in my Risk assessment, not sure which controls can prevent 'Foreseeable misuse by the consumer' hazard? Please help.
We are a injection moulding business, we manufacture plastic caps for food and house hold products. All are B2B sales. Nothing shipped direct the consumer.
It is difficult to come up with any consumer misuse hazards for your products. The only vague area I can think of is deliberately over-riding any tamper evident systems and the consequences to your customers.
Are they printed?
Have a look at your complaints history to see if there is anything relevant.
If at the end of the day, if there are no hazards, it is perfectly OK to say 'none identified, or some similar phrase, and then move on.
Hi,
Thank you for your prompt reply.
No the caps are not printed.
All sales are B2B, not to the direct consumer. I am thinking to call its as not identified or low risk?
The point about you selling to B2B customers as opposed to final consumers doesn't negate the need to assess the risk to the final consumer and the Standard has deliberately used the word 'consumer' not 'customer' in this clause. If you think about it, very few packaging materials are sold directly to consumers, most are sold to packers of some description.
To take the example of tamper evidence for instance, if you make caps with snap off lugs for tamper evidence, you may have a minimum torque level to guarantee that they will always break when twisted so that anybody wishing to deliberately contaminate the product will not be able to remove the cap without it being noticed. (It may also be that your caps are used on a product which, if opened, will start to go off and the snapped lugs would indicate that somebody has opened the bottle)
The fact that they have been designed into the product suggests that there is a perceived potential hazard. You then need to evaluate the level of risk of this hazard by looking at the likelihood and severity of it occurring in your normal way.
If they are not tamper evident types, I can't think of any other potential consumer misuse scenario and in this case saying 'none identified' is perfectly OK, but as I said earlier, look at your complaint history, there may be examples there that are relevant.