Hazard Analysis

Dear Simon,
We are in the process of just starting with the Hazard Analysis when assessing the risk and severity of an ingredient and process we have adopted the following approach -
1.We are assesing the risk(likelihood of occurance) based on the controls that have been put in place
2.We are assesing the severity keeping in mind what damage could the presence of a hazard cause on the packed product. Is this the right approach?
One consultant, I met, told me that the mere presence of a hazard (example splinters from broken pallet) meant that the severity had to be critical irrespective of whether it will affect the packed product or not? I am confused
Pls advise

Rgds

Shivendra

Hi Shivendra,

It seems like you're heading down the right track. Using Likelihood X Severity to arrive at a Risk Rating is an OK method.

With regard to the pallet splinters, I'm not sure what the consultant is talking about, like we said it's about hazard analysis and determining risk - if it's not likely and / or not severe then how can it be critical?

Maybe it would be helpful if you could tell us more about your product and process. Also what Standard are you working to e.g. BRC / IFS / HACCP? What is your objective?

Regards,
Simon

Hi Shivendra,

It seems like you're heading down the right track.  Using Likelihood X Severity to arrive at a Risk Rating is an OK method.

With regard to the pallet splinters, I'm not sure what the consultant is talking about, like we said it's about hazard analysis and determining risk - if it's not likely and / or not severe then how can it be critical?

Maybe it would be helpful if you could tell us more about your product and process.  Also what Standard are you working to e.g. BRC / IFS / HACCP?  What is your objective?

Regards,
Simon

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Dear Simon,
We are going into Flexible packaging and are opting for BRC-IOP Food packaging Global standard. The products are Laminates, Mono layer printed films etc. We have process like printing, lamination, slitting, packing, pouching etc. which are common in Flexible packaging companies world wide. We are suppliers to the Food producers in India for packing of their product.

Regards

Shivendra

That's great Shivendra. Feel free to ask as many questions as you like and we'll help you all we can.

Going back to the wood splinter issue. In the UK prior to the BRC/IoP Standard it was often required by customer auditors for wooden items such as pallets, crates, and even in some cases wooden handled tools, brooms etc. to be totally excluded from food packaging production.

In the BRC/IoP Global Standard - Food Packaging for category B supplier such as your company the requirements are:

5.4.2
Wooden desks, chairs, tables, and other items shall be kept clean, in good condition and free from splinters or other sources of physical contamination.

5.4.3
Wooden equipment including desks, chairs, tables etc. shall be properly sealed as to enable them to be effectively cleaned.

Best Practice Guidelines
Wherever practicable wooden equipment and other items should be removed from production areas.

As you can see exclusion of wooden items is now only a best practice guideline. In other words you don't have to do it. However, I would advise you exclude wood wherever possible, protect where it is not possible and definitely unpack raw materials outside of production (or in a segregated area) as this process is usually quite messy and could potentially pose a risk to product.

Also be sure to check out clause 6.4.3 and the corresponding Best Practice Guidelines on wooden pallet standards.

Hope this helps.

By the way as you probably know our company is into employee hygiene awareness training and I wondered what's available in India and how for example you train your employees?

Regards,
Simon

By the way as you probably know our company is into employee hygiene awareness training and I wondered what's available in India and how for example you train your employees? 

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Dear Simon,
We do not any exclusive firms in India that cater to the Hygiene training. What we are doing is putting the necessary hygiene practices as required by the Standard. There are no compromises done anywhere.
Case: Jewellery control : Totally banned in the plant
Case: Hair Policy: Hair nets/caps in place
Case: Mobile usage: Totally banned on the shop Floor

The good thing is that people are whole heartedly accepting the practice as it is mandatory requirement
We are in the process of putting some controls on the sub-contractors etc. What do you think is the most cost effective way out? We might be having our own ideas but some benchmarking is not a bad idea et all.

rgds

Shivendra

rgds

Shivendra

We do not any exclusive firms in India that cater to the Hygiene training. What we are doing is putting the necessary hygiene practices as required by the Standard. There are no compromises done anywhere.

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I understand that you are putting the required hygiene practices in place, but you are also required to provided all personnel with hygiene training. see 7.8 of the Standard. I wondered how you were covering this aspect.

We are in the process of putting some controls on the sub-contractors etc. What do you think is the most cost effective way out? We might be having our own ideas but some benchmarking is not a bad idea et all.

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It gives clear requirements and guidance on this in 4.11 of the Standard, see the Best Practice Guidelines in this section for ideas.

Regards,
Simon