CCP for Corrugated Cardboard
Dear all, I hope all to be in very good health and doing well. Kindly I need your help to determine CCP in manufacturing of Cardboard industrial starting in corrugation board then printing and die cutting . I plan to get BRC issue 6. Thanks , Mohamed Zaki.
What did your hazard analysis tell you? You need to do this first
Remember, a CCP is for food safety. I have a hard time seeing any critical risk to food safety with carboard assuming it is used as secondary or tertiary packaging.
Dear all, I hope all to be in very good health and doing well. Kindly I need your help to determine CCP in manufacturing of Cardboard industrial starting in corrugation board then printing and die cutting . I plan to get BRC issue 6. Thanks , Mohamed Zaki.
Hi Mohamed,
This website may assist -
I disagree with post 3 in that a CCP is not just a food safety parameter, they can apply to product safety in all manner of sectors - packaging, consumer products, cosmetics etc.
The example that I tend to use to explain this relates to printing so may be relevant to the original post.
If a print line runs two consecutive jobs, one for a peanut product and one for an allergen free product there needs to be 100% effective segregation, so a detection and elimination process needs to be in place and proven to be working. (There are automatic or manual systems available depending upon the industry)
If the products are mixed at the printers (I have seen this in several operations) they will reach the food packer who may not have the systems to pick out incorrect packaging (Again, I have seen this in several food packers, large and small) before it is packed
Failure to control and prevent mixing may kill somebody.
There are other examples in different sectors as packaging is not only used for food.
It would be difficult to argue in a prosecution that you don't consider a potential death to be critical.
I disagree with post 3 in that a CCP is not just a food safety parameter, they can apply to product safety in all manner of sectors - packaging, consumer products, cosmetics etc.
The example that I tend to use to explain this relates to printing so may be relevant to the original post.
If a print line runs two consecutive jobs, one for a peanut product and one for an allergen free product there needs to be 100% effective segregation, so a detection and elimination process needs to be in place and proven to be working. (There are automatic or manual systems available depending upon the industry)
If the products are mixed at the printers (I have seen this in several operations) they will reach the food packer who may not have the systems to pick out incorrect packaging (Again, I have seen this in several food packers, large and small) before it is packed
Failure to control and prevent mixing may kill somebody.
There are other examples in different sectors as packaging is not only used for food.
It would be difficult to argue in a prosecution that you don't consider a potential death to be critical.
Please explain the source of potential death? I already know the answer....I’m just seeing if you connect the dots. Is it....the ink or packaging that kills? Or....the food product inside the packaging?
And yes, there are other items which have safety hazards, but they are not good. HACCP can be used for other industries, but it typically is not. HACCP and CCP is models recognized as a food safety system.
Also note that retailers' classification of vegan includes the packaging in which the consumer purchases vegan products.
Ref Ryan's post 6
Clearly it is the commodity inside an incorrectly labelled printed package, consumption of packaging generally doesn't happen in sufficient quantity to kill. If an item of printed packaging is mixed at the printers it may not be detected at the food packer and consequently an allergenic product may be unknowingly be packed and consumed.
There are elements of food contact packaging which can cause harm but rarely death eg endocrine disruptors such as BPA.
As I said previously, packaging is used for sectors other than food such as pharmaceuticals, cosmetics etc. Many tablets look the same and putting say, digoxin, in a container labelled as paracetamol could be fatal. Similarly mixing dosages of the same medicine can also be fatal. Hence controlling that process point is critical for the printer.
I agree that HACCP is essentially a food safety system, but the original post was about CCPs and CCPs can be the result of many different risk based product safety systems
CCPs for Packaging has always been a controversial topic. Not always plain-sailing for Food either. :smile:
I note that Glossary in BRC Packaging Standard has this "thoughtful" definition -
critical control point (CCP) - A step at which control can be applied and is essential to prevent or eliminate a food or product safety hazard or reduce it to an acceptable level.
("acceptable level" is perhaps less "comfortable" for the latter option)
[Somewhat (IMO) amazingly, the Glossaries for SQF's Food and Packaging Standards both omit "critical control point (CCP)" (and "control measure/point" for that matter)].
Also see -
https://www.ifsqn.co...ps/#entry102500
PS - sadly BRC (IMO) subsequently spoilt the above semantic elegance by going [safety] "hazard overboard", eg -
2.2.6 The HARA team shall identify and record all potential product safety hazards that are reasonably expected to occur at each step in relation to the product and process.
The hazards considered shall include, where relevant:
• microbiological hazards
• chemical contamination (e.g. taint, odour, allergen, component transfer from inks, varnishes and glues)
• potential for unintended migration of substances from the packaging material into food or other hygiene-sensitive products
• foreign objects
• potential problems arising from the use of recycled materials
• foreseeable misuse by the consumer
• defects critical to consumer safety
• hazards that may have an impact on the functional integrity and performance of the final product in use
• potential for malicious intervention
• potential for raw material fraud.
One of the hazard in packing material is contamination due to printing matter on corrugated boxes. Critical limits in such cases could be the acceptance of print migration test. This would be helpful if its a primary packing material. For secondary, I'm not quite sure if Hazard analysis is required.
Members may give more inputs.
One of the hazard in packing material is contamination due to printing matter on corrugated boxes. Critical limits in such cases could be the acceptance of print migration test. This would be helpful if its a primary packing material. For secondary, I'm not quite sure if Hazard analysis is required.
Members may give more inputs.
Supplier Approval ? = PRP ?
I would suggest perfomring the risk assessment of each and every steps of your flow diagram and based on that result you would decide to have or not to have CCP in your process.
For packaing industry i have hardly seen CCP in process. you are cardboard packaging so assuming secondary packaging. i dont thin you will need CCP in your process. you should rather have control points to control various hazards in your process flow diagram.
Thank you
Arpit
I would suggest perfomring the risk assessment of each and every steps of your flow diagram and based on that result you would decide to have or not to have CCP in your process.
For packaing industry i have hardly seen CCP in process. you are cardboard packaging so assuming secondary packaging. i dont thin you will need CCP in your process. you should rather have control points to control various hazards in your process flow diagram.
Thank you
Arpit
LOL, I bet the last auditor auditing my company would get panicked seeing zero CCPs and raise a major NC. Some people can't think outside the box.