Packaging HACCP Plan from Consumer's Viewpoint

Dear All,

Not really my area but was interested to see that allergens have now "crossed over" into packaging HACCP.

http://www.pac.ca/Se...P_KFExample.doc

Rgds / Charles.C

Dear All,

Not really my area but was interested to see that allergens have now "crossed over" into packaging HACCP.

http://www.pac.ca/Se...P_KFExample.doc

Rgds / Charles.C

Great free document there for packaging companies. I'm part way through and will revert when I've read it all. Allergen control in packaging is an important emerging issue.

Thanks Charles,
Simon

That was a really good article - really recognises issues that have occurred. Some food manufacturers now have packaging ccps to check that packaging is correct (eg. operators check all packaging every hour against specification) and this makes sense when you consider the problems that have occurred in teh past with mixed pallets of packaging, or mixed reels of packaging. Allergen hazard cross over into the packaging HACCP plan is a very logical and necessary move.

The document was obviously developed by Kraft and they are playing a major role in of the development of the PAC Standard – I think it’s a Canadian standard.

I've always been very impressed with the Kraft Code of Practice for suppliers of packaging and this HACCP Plan again is extremely comprehensive, relevant and quite readable. It put’s the free packaging HACCP plan on here to shame; well at least it takes it to the next level.

Packaging Printers can learn a lot from this wonderful free document and it will save those developing a food safety management system a lot of time and effort – great job!

I just have a couple of issues.

1. Not sure what the PP is in little boxes on the process flow chart…oh wait does it stand for Prerequisite Procedure?

2. I don’t understand pages 12-14 on allergen review. If it’s saying what I think e.g. printer / packaging supplier are responsible for listing allergens etc. for every part code then I don’t see why. For me their responsibility is to print with the correct plates and to ensure they do not mix any printed / finished packaging. It has to be the food companies responsibility to ensure the artwork is correct (e.g. correct ingredients for product / including any allergen warnings) and for ensuring the correct food product formulations are maintained and packed in the correct packaging and there is no cross contamination. Maybe I’ve read it incorrectly. How do others see it?

Regards,
Simon

1. Not sure what the PP is in little boxes on the process flow chart…oh wait does it stand for Prerequisite Procedure?

Well if it doesn't then we're both wrong !

I don’t understand pages 12-14 on allergen review. If it’s saying what I think e.g. printer / packaging supplier are responsible for listing allergens etc. for every part code then I don’t see why. For me their responsibility is to print with the correct plates and to ensure they do not mix any printed / finished packaging. It has to be the food companies responsibility to ensure the artwork is correct (e.g. correct ingredients for product / including any allergen warnings) and for ensuring the correct food product formulations are maintained and packed in the correct packaging and there is no cross contamination. Maybe I’ve read it incorrectly. How do others see it

Im not an expert on printing but as I read it they are asking for allergens in the printing inks and substrates, the Hazzard Analysis charts on pages 7-11 have allergens and sulfites in the list of chemical contaminants and the process steps are those for the printed film production.

I've always been very impressed with the Kraft Code of Practice for suppliers of packaging and this HACCP Plan again is extremely comprehensive, relevant and quite readable.

The Kraft UK packaging supplier requirements are certainly comprehensive, the HACCP section alone runs to 73 pages ! I like the way they give us their audit protocol as well, we find Kraft (UK) a very transparent company to deal with on technical issues.

Cheers Martin, I'm going to give it another read to try and understand it better.

Hi All,

Certainly a good piece of work that can help many packaging suppliers.
I would like to add some points.

For example:
1. Pinholes that are made by a roller some where in the production process, there should be some control on pinholes.
2. Blocking of the ink in case of film, what is printed on the outside transfers to the inside on the roll and comes into direct contact to the packed food stuff. (this problem is mentioned specifically in the latest GMP EU regulation)
3. This accounts also for the starch powder.
4. The used polymers, I would list the chemical hazards (monomer residue), control method is migration testing on finished product.

Remember to share good fortune with your friends, Okido

For example:
1. Pinholes that are made by a roller some where in the production process, there should be some control on pinholes.
2. Blocking of the ink in case of film, what is printed on the outside transfers to the inside on the roll and comes into direct contact to the packed food stuff. (this problem is mentioned specifically in the latest GMP EU regulation)
3. This accounts also for the starch powder.
4. The used polymers, I would list the chemical hazards (monomer residue), control method is migration testing on finished product.

Thanks for your insightful comments Okido. I have a few comments and questons;

1. Do you mean caused by print rolers or embossing rollers?
2. Spot on
3. Yes
4. Migration testing every batch, or at specific intervals, or before initial approval of the material and work to agreed specification thereafter?

Regards,
Simon

Hi Simon,

Regarding pinholes I would include all rollers, print rollers, guide rollers, embossing rollers.
Falling tools for instance or just some welding activities can mechanically damage rollers during maintenance.
Rubber like rollers can pick up dirt or metal splinters. Depending of film properties a hole relatively easy to make.
Mineral deposits on rollers can form very sharp edges when the break away.
Migration testing can be done at specific intervals, 1 to 3 years, if you do not change polymers every other month and your supply chain is reliable.
Migration specifications and restrictions for most raw materials are precisely described in EU directives.
If raw materials not listed in EU directives you have to prove that they are safe to use.


Best regards, Okido

There are only 10 types of people in the world that understand binary code, people who do and people that do not.

Regarding pinholes I would include all rollers, print rollers, guide rollers, embossing rollers.
Falling tools for instance or just some welding activities can mechanically damage rollers during maintenance.
Rubber like rollers can pick up dirt or metal splinters. Depending of film properties a hole relatively easy to make.
Mineral deposits on rollers can form very sharp edges when the break away.

I just wanted to pursue the pinholes a little Okido. How would you minimise the risk of pinholes e.g. cleaning plan for rollers and especially after maintenance, storing reels off the floor on clean pallets, testing of raw material for leakers??

Simon

I just wanted to pursue the pinholes a little Okido. How would you minimise the risk of pinholes e.g. cleaning plan for rollers and especially after maintenance, storing reels off the floor on clean pallets, testing of raw material for leakers??

Simon

Hi Simon,

To minimize the risk of pinholes I would:

· Clean and inspect rollers before start-up,
· after every production interruption were the film is fed through the machine check for pinholes,
· check on pinholes after maintenance, especially drilling activities,
· cover machines during welding activities, (hot-works permit),
· make people aware that knife tips easily break off without noticing it when you hit a rubber roller,
· store rolls only on clean pallets whit cardboard or wooden plate,
· keep the working area clean,
· avoid temporary engineering with sticky tape, etc.

Basically it is straightforward good manufacturing practice and not rocket science.


Best regards, Okido

There are only 10 types of people in the world that understand binary code, people who do and people that do not.

Basically it is straightforward good manufacturing practice and not rocket science.

Sounds good Okido. What about testing new / refurbished embossing rollers before releasing to production. Emboss some material, seal samples of full roller repeat to containers filled with water or maybe a red food dye mixed with isopropynal. I have seen this. Is this validation, verification or overkill?

Regards,
Simon

What about testing new / refurbished embossing rollers before releasing to production. Emboss some material, seal samples of full roller repeat to containers filled with water or maybe a red food dye mixed with isopropynal.

Morning Simon,

Sealing samples of the full roller repeat sounds well.
Filling containers with water or any other liquid can be done but depends on application and testing method.
Could you be more precise what product is tested?
For testing with high-pressure, water like liquids are OK but if it is atmospheric testing than you should use a gas.
Compressed air is the most simple gas mixture to use, blow up the bags, pouches, and containers under water and look for bubbles.

Have a nice week, Okido

Sealing samples of the full roller repeat sounds well.
Filling containers with water or any other liquid can be done but depends on application and testing method.
Could you be more precise what product is tested?
For testing with high-pressure, water like liquids are OK but if it is atmospheric testing than you should use a gas.
Compressed air is the most simple gas mixture to use, blow up the bags, pouches, and containers under water and look for bubbles.

Hi Okido, I'm talking about flexible packaging for sealing to containers e.g. lidding for yoghurts, cream and other food products. If you seal some material to the container and then cut the container down to make a dish and then fill with a mix of red dye and isopropynl and leave for a while. The red dye solution is very searching and obviously allows one to see any pinholes very easily. But you are right one could seal containers with material from the roller repeat and test in a vacuum chamber or like you say under water and look for bubbles.

Have a nice week too my friend.

Regards,
Simon

If you seal some material to the container and then cut the container down to make a dish and then fill with a mix of red dye and isopropynl and leave for a while. The red dye solution is very searching and obviously allows one to see any pinholes very easily.

Hi Simon,

I have experience with lidding on trays. But testing with fluids has never been an option.
It is simply not accurate enough.
Have you ever repaired a punctured bicycle tire?
Testing with air/water gives you accurate results without much hassle, no need to validate this test method in my opinion.
If you want to test with high pressure, for instance to test PET bottles, you could take a fluid for safety reasons.

Best regards, Berry

I have experience with lidding on trays. But testing with fluids has never been an option.
It is simply not accurate enough.

I have since learned the red dye solution was used to see damage or cracks in the aluminium foil more easily under the microscope. So it was already known there was a problem, if you get what I mean.

Cheers Berry.

Simon