8 replies to this topic

[serdem]

Hello, I work for a company that produces cardboard packaging. Do you have a sample HACCP plan for this production process?

[MDaleDDF]

An entire HACCP plan is a difficult thing to post.  You're going to need to go through the entire process of a hazard analysis, determination of CCP's, etc, and it's going to vary greatly from plant to plant.

Have you taken an online class or anything to understand the development of a plan?   It's no small undertaking...

[MlissaB]

First off, I would reconsider doing HACCP. I also work for a corrugated manufacturer and we have been transitioning to HARA because after years of both AIB inspections and GFSI certification we have never found a CCP in any of our processes. 

 

From there we simply created a process flow and from there listed all material types (paper, glue, ink, etc.), all Risk topics, all Hazard types (generally listed in the standard) and completed a risk assessment (Likelihood and Effect) of the risk and determined how any risks were managed. We found that all are managed through either our PRPs or other operational procedures. 

 

Hope this helps.

[GMO]

First off, I would reconsider doing HACCP. I also work for a corrugated manufacturer and we have been transitioning to HARA because after years of both AIB inspections and GFSI certification we have never found a CCP in any of our processes. 

 

From there we simply created a process flow and from there listed all material types (paper, glue, ink, etc.), all Risk topics, all Hazard types (generally listed in the standard) and completed a risk assessment (Likelihood and Effect) of the risk and determined how any risks were managed. We found that all are managed through either our PRPs or other operational procedures. 

 

Hope this helps.

 

Honest question, I have no problem which you use as an auditor but why does not finding a CCP mean you shouldn't use HACCP?

[selenaduong1986]

HI serdem, 

 

You can find some example on https://www.iopp.org..._201_ haacp.pdf

[MlissaB]

Honest question, I have no problem which you use as an auditor but why does not finding a CCP mean you shouldn't use HACCP?

 

GMO - in general it does not, however we produce corrugated packaging for non-contact applications only. I have been through both HACCP and HARA training and the trainers have confirmed that in our industry the likelihood of a CCP is very low and without it HACCP is overkill. Even for the couple of sites that do packaging for direct contact with food, there still aren't CCPs and all risks are controlled through PRPs or other standard processes. 

 

Our sites are certified to BRC for Packaging and the requirement of that standard is a HARA team and HACCP only come in if there is a critical control. Our products do not have things like dwell time or hot/cold limits for the safety of the product. Many of the settings are adjusted based on environmental conditions (things run differently in the cold, dry winter months than the hot, humid summer months) and the "risks" are quality issues, not the safety of the product or the customers product going in it. 

 

The OP stated cardboard packaging which is either corrugated or single layer paperboard (which we also do, those sites just aren't GFSI certified at this time). I've been in the industry for over 25 years and many auditors have stated it's overkill for our business. We started with HACCP back in the days of AIB inspections when that's what was called out and the thought was that at some point we would become an ingredient. That school of thought seems to have shifted to HARA, understanding that HACCP may be too much for what we are doing. 

 

I could understand HACCP for flexible plastic packaging or vacuum sealed containers where they have to be heated to a specific temp to ensure integrity, that just isn't the case in our industry. 

[GMO]

Thanks for the explanation.  I don't have any strong feelings about it any way but I have to admit even some food contact packaging suppliers or suppliers where food safety or legality information is printed on their packaging have been quite resistant to HACCP (or any system, not even HARA) when it's not actually that difficult a system and not broken either.  Most food safety controls in food factories are also PRPs as well.  But I suppose purists / engineers must always wonder why food safety people took FMEA and simplified it in the first place.

 

Anyway, not my area of expertise.

[MlissaB]

Thanks for the explanation.  I don't have any strong feelings about it any way but I have to admit even some food contact packaging suppliers or suppliers where food safety or legality information is printed on their packaging have been quite resistant to HACCP (or any system, not even HARA) when it's not actually that difficult a system and not broken either.  Most food safety controls in food factories are also PRPs as well.  But I suppose purists / engineers must always wonder why food safety people took FMEA and simplified it in the first place.

 

Anyway, not my area of expertise.

 

I get it. I can also see other packaging industries where there may be the requirement (like I said, flexible packaging and dwell times or the bags that let the product "breathe"). A clear picture for me is when you look at the plan selenaduong1986 shared above under section 7 we would perform a-h then stop because we had no CCPs which makes our plan HARA. If you look at the example it is cans, which also makes sense because the seals are critical. Corrugate/cardboard just has a lot more flexibility in our tolerances that there isn't much for critical control. 

 

Even when you mention the printed content, that isn't a CCP because the art approval process is standard and the rest is PRPs, the printing of correct graphics does not have a measurable limit so it can't be a CCP. In our case we only take responsibility for printing what the customer approved, we have no way of knowing if it is accurate for the product they are packing into the packaging because that is no our realm of control or expertise. Back in the day when an AIB auditor convinced us we HAD to have a CCP we tried using the artwork for just this reason and in my formal training they said that was a big NO. 

[GMO]

No, I get it wouldn't be a CCP, it was more a resistance to them having any impact on food safety (which is obviously false), I can't see any circumstances where any process in a packaging company would be a CCP.  But likewise there are food manufacturing companies who have no CCPs too, same (frequently) with warehousing, distribution and traded goods.  They don't reinvent the wheel though. 

But anyway, I've highjacked this thread enough.