HACCP for secondary plastic packaging

Hi all, 

I am working on implementing non food safety and quality standard(something like HACCP) for secondary packaging manufacturer that produce recycle retail/grocery bag which is indirect contact with food. our processes include recycle > extrusion > printing > bag making.

How can i identify the steps as CCP since the bag is not direct contact with food? 

Is the presence of bacteria during recycle process considered as hazard if the next process will eliminate the bacteria (eg: heating)?

Thanks.

Hi shiorishira90,

:welcome:

Welcome to the IFSQN forums.

The presence of bacteria during the recycle process is a hazard and is noted but your HACCP would document that the hazard is removed by the temperature of the process.

Should you consider the bag and ink as food contact as some items may be purchased loose such as fruit? If so then hygiene and chemical migration may be important factors to consider.

Kind regards,

Tony

Depending on your process there may not be a CCP.  That's pretty common in the plastic packaging industry.  Just something to keep in mind and transitioning from food manufacturing to food contact film, can be hard to swallow that there would be no CCP.