8 replies to this topic

[Sodje_0]

Hello forum. I am in the process of introducing a CCP to our HARA plan in a packaging company. The CCP is required to control composite print at the gluing stage. The hazard is controlled through the use of a barcode reader which identifies cartons via a barcode printed onto the glue flap. If the reader identifies an incorrect barcode it rejects 12 cartons before stopping the line.

 

My specific question concerns 2.2.9 of the Standard

'For each CCP, the appropriate critical limits shall be defined in order to identify clearly whether the process is in or out of control. Critical limits shall be measurable, where possible, and the rationale for their establishment clearly documented. Relevant legislation

and codes of practice shall be taken into account when establishing the limits.'

 

The critical limits we have established are the machine stopping after a minimum of 12 cartons or after a maximum of 20 cartons. I'm not sure that how relevant legislation and codes of practice would apply in this instance, so I am wondering if what we he have done would comply with this clause?

 

Has anyone undergone a similar experience with composite print? Any advice would be greatly appreciated. 

[Evans X.]

Greetings Sodje,

 

The key word is "relevant". If there is no relevant legislation or code of practice then you only have, as mentioned in the previous sentence, to clearly document the rationale for their establishment and explain in detail how it works and the tests you made to see if it works. Some things may not fall in a certain known category and be discussed widely, cause it can be an in-house matter that applies in your case.

However, as with all CCPs, you have to thoroughly detail how you control it and how this was validated. Does the reader reset everytime it reads a new error or it stops reading and rejects the next 20? Stopping after 20 is because you have multiple errors during the first 12?

Things like this you need to clear out and if you already have write them down in detail.

Also, but this is my opinion, does this control point really pose a health risk? I believe it could be an OPrP possibly.

 

Regards!

[G M]

The relevant legislation probably falls back to very general legal standards like accurately representing your goods.

 

Its difficult to be more specific about legal expectations when we don't know what legal jurisdiction you're in.

[Tony-C]

Hi Sodje_0,

 

If you can demonstrate from documented production trials that the system you have with 12 rejected cartons prevents an incorrect barcode from getting through then that should be fine. It will also help if you have guidelines from the supplier of the barcode reader/rejection equipment.

 

From BRCGS Global Standard for Packaging Materials Issue 6 Guidance:

Clause 2.2.9 Establish critical limits

All identified CCPs must have defined critical limits. Criteria in packaging often include dimensional measurements, printing errors and performance-related faults such as leaks. Details on how critical limits have been reached need to be referenced and may include consideration of production trials and industry best practice.

 

Kind regards,

 

Tony

Edited by Tony-C, 01 November 2023 - 03:20 AM.

[Sodje_0]

Greetings Sodje,

 

The key word is "relevant". If there is no relevant legislation or code of practice then you only have, as mentioned in the previous sentence, to clearly document the rationale for their establishment and explain in detail how it works and the tests you made to see if it works. Some things may not fall in a certain known category and be discussed widely, cause it can be an in-house matter that applies in your case.

However, as with all CCPs, you have to thoroughly detail how you control it and how this was validated. Does the reader reset everytime it reads a new error or it stops reading and rejects the next 20? Stopping after 20 is because you have multiple errors during the first 12?

Things like this you need to clear out and if you already have write them down in detail.

Also, but this is my opinion, does this control point really pose a health risk? I believe it could be an OPrP possibly.

 

Regards!

 

Thanks for this Evans and just to add a bit more context in answer your questions. The gluing line shuts down after the reader recognises 12 incorrect barcodes. 20 is the maximum before we would consider the critical limit to fail, if the line doesn't shut down after this. 

 

We produce food packaging and the health risk comes from the potential for undeclared allergens should a product mix occur. 

[Scotty_SQF]

I guess I am confused why this would be defined as a CCP.  What is the critical food safety hazard you identified for your packaging?  To me, this sounds more like a print quality check and thus not needing it spelled out a s a CCP.   I see CCP's as points where you are controlling serious adverse conditions such as foreign material, bacterial risk, etc.  

 

From what I am understanding you are concerned with an error in the print in terms of allergen declaration?  I understand what you are trying to say/do and I think you have a good system in place, just confused why it would be defined as a CCP as there is actually not product in the packaging yet, thus it is yet to be a concern.  That's why I feel it would be more of a quality check.  In turn the customer receiving your packaging I am sure has a robust labeling check as they receive your packaging.  I guess it depends on what agreements you have with your customers.  In a place I worked at before where we printed the agreement was on the customer to provide the correct artwork and we in turn made sure that we printed per the approved customer proof.

[Sodje_0]

I guess I am confused why this would be defined as a CCP.  What is the critical food safety hazard you identified for your packaging?  To me, this sounds more like a print quality check and thus not needing it spelled out a s a CCP.   I see CCP's as points where you are controlling serious adverse conditions such as foreign material, bacterial risk, etc.  

 

From what I am understanding you are concerned with an error in the print in terms of allergen declaration?  I understand what you are trying to say/do and I think you have a good system in place, just confused why it would be defined as a CCP as there is actually not product in the packaging yet, thus it is yet to be a concern.  That's why I feel it would be more of a quality check.  In turn the customer receiving your packaging I am sure has a robust labeling check as they receive your packaging.  I guess it depends on what agreements you have with your customers.  In a place I worked at before where we printed the agreement was on the customer to provide the correct artwork and we in turn made sure that we printed per the approved customer proof.

 

Scotty, The rationale for it being a critical food safety hazard is a follows. A composite print job could be be 4 different designs on the same printed sheet which all appear very similar. You are correct in saying that it is a print quality check, which of course we have built into our systems. The customer is also responsible for final artwork approval. However, the food safety hazard in is not from printing but rather the potential for product mixing at the gluing stage. The barcode reader on the gluing line is the failsafe in detecting an incorrect barcode and stopping the machine. If this was to fail, it leaves the possibility of two different designs being packed into the same case. The ingredients listed on each design differ so there is a potential for undeclared allergens if two different products are mixed and packed together. 

 

Personally I argued against the use of composite print but it was introduced for operational reasons. The order quantities are small and it's not cost effective to print each each design separately. 

[Scotty_SQF]

Ah ok.  Yeah printing composite makes things a bit messy.

[Tony-C]

Hi Sodje_0,

 

If you can demonstrate from documented production trials that the system you have with 12 rejected cartons works then that should be fine. It will also help if you have guidelines from the supplier of the barcode reader/rejection equipment.

 

From BRCGS Global Standard for Packaging Materials Issue 6 Guidance:

Clause 2.2.9 Establish critical limits

All identified CCPs must have defined critical limits. Criteria in packaging often include dimensional measurements, printing errors and performance-related faults such as leaks. Details on how critical limits have been reached need to be referenced and may include consideration of production trials and industry best practice.

 

Kind regards,

 

Tony