26 replies to this topic

[okido]

Hi Saferpakker’s,

The first step in traditional HACCP for food is conducting a hazard analysis.
Hazards that can be identified are biological, physical or chemical in nature.
This way of identifying hazards has proven its merits.
But is it good enough for the packaging industry.
There is one more factor that can influence food safety that should be included in the hazard analysis.
This factor is product defects.

For example:
- Films for closing trays, pinholes in the film can cause oxygen to enter the package and make the packed product un-safe
- Coffee cups with EVOH barrier, a defective barrier will cause the milk to go bad

In both cases a product defect causes the food to deteriorate over time.
The defects cannot be categorized as being biological, physical or chemical in nature in the traditional way. For the packaging industry it is essential that potential product defects are part of the hazard analysis.
Identifiable hazards are biological, physical or chemical in nature and product defects in the packaging industry.

Should we rewrite our textbooks now?

Have a nice day, Okido


There is only one source and that is Open Source.

[MartLgn]

Should we rewrite our textbooks now?

There's a textbook ? what's it called? where can I get one ?

I don't think the problem lies with the scope of HACCP rather the adoption of HACCP by the packaging industry in the absence of anything more suitable, the methodology is ideal but the detail is inevitably skewed toward food production.

I think that the BRC/IOP standard has this covered from a packaging standpoint. Section 3 avoids any mention of HACCP and clause 3.11 requires 'a formal hazard analysis on the production process considering microbiological,foreign objects and chemical contamination, product integrity,legallity and defects critical to consumer safety'

That seems to have pretty much everything covered including something for the lawyers!

[Charles.C]

Dear Okido,

There is only one source and that is Open Source.

I assume you are not too positive with respect to ISO 22000

Best Rgds / Charles.C

[Simon]

Packaging HACCP is a bastard. It was adopted by us saferpakers because 1. foodies told us we needed to do it, 2. There was nothing else, 3. It's quite good.

As well as C, P, M do any foodies analyse Q - Quality criteria in your HACCP plans?

Okido, add wrong print "ingredients" to the list of examples. A quality defect that does not cause deterioration of the food over time, but could cause illness or injury to the consumer - allergens?

Regards,
Simon

[MartLgn]

Packaging HACCP is a bastard. It was adopted by us saferpakers because 1. foodies told us we needed to do it, 2. There was nothing else, 3. It's quite good

Is that a rejected early draft of the inrtoduction to section 3 of the forthcoming new BRC/IOP standard ?

[Simon]

Is that a rejected early draft of the inrtoduction to section 3 of the forthcoming new BRC/IOP standard ?

No it's still in as far as I know. On that subject have you got wind of a date for BRC Packaging V3 yet Mart?

[MartLgn]

have you got wind of a date for BRC Packaging V3 yet Mart?

Nothing definite no, back in April a little bird told me it would be towards the end of this year but I've heard no advance on that since.

[okido]

Hi MartLgn,

I agree with you that BRC IoP has covered pretty much every thing. I would be pleased with ISO22k if it had learned just a little more from the BRC IoP standard. The draft EN15593:2006 does little better, it is a close copy of BRC IoP.
An advantage is that the ISO standards are available in my mother tongue, BRC IoP unfortunately not any more. It was handy to use in my mother tongue and convincing for non English readers, now I have to translate.

There's a textbook ? what's it called? where can I get one ?

Not much available for packaging, should I write one?

Besides the sources of contamination C, P, M, I would be pleased to see Q also into HACCP.
Not just for non-food but also for food as for instance the allergen print mistake Simon came up with.


Have a nice day, Okido

[Simon]

Nothing definite no, back in April a little bird told me it would be towards the end of this year but I've heard no advance on that since.

Something to look forward to.

Not much available for packaging, should I write one?

Yes why not; do you think anyone would buy it, or is just something to get you into the history books?

Regards,
Simon

[hSusan]

HI..catching up on my forum reading so this is a bit out of date..

I audit a lot of packaging manufacturers and many struggle with the hazard analysis apart from identifying the usual contamination suspects like glass, grease, pests etc.

Something that makes sense to me..is for packaging manufacturers to use the "product description" and "intended use" steps to 'fill out' their picture of how their packaging is used. Ie. to picture their product as it would be used by their customer, and therefore develop some understanding of how they support their customers in achieving and maintaining food safety.

(I suspect this is a natural way for the 'through chain' communication clause in ISO22k to be met anyway)

After all the PD & IU's are an essential tool for the HACCP team to base their hazard analysis on.. so it should be a wholistic picture of their product - not the isolated one.

The key is possibly to put together their product with the customer's product ie. if they do the closures, picture their closures on some of their customer's bottles and picture the bottles filled with the relevant product - is it milk? carbonated soft drink? chilled pasteurised high acid juice? water? What does the end consumer do with the product and how do they interact with our packaging manufacturer's product?

For instance..if the manufacturer pictures premium organic baby food in the glass bottle with their lid on it.. this is a usefully different picture from generic brand strawberry jam with their lid on it.

I am interested to hear what other members think about this..is this something you already see packaging manufacturers do?

[Simon]

Hi Susan, Thanks for your comments you have opened up a great area for further debate in my opinion.

I’m guessing since the advent of the BRC Packaging Standard a lot of packaging manufacturers who use this standard do use the "product description" and "intended use" steps as per pure HACCP. However, I wonder like you how in depth they go as in your example of a jar used for retailer own brand ‘cheap and cheerful’ jam and the same jar used for organic baby food.

Here are the relevant clauses from the latest version (issue 3) of the BRC Packaging Standard.

1. HAZARD AND RISK MANAGEMENT SYSTEM

1.6 The team shall identify hazards that may have an impact on the functional integrity and performance of the final product taking into account the customers requirements and manufacturing processes.

1.7 The hazard and risk analysis shall consider microbiological, foreign objects and chemical contamination, legality and defects critical to consumer safety. The hazard and risk analysis shall be based on the range of uses of the packaging product promoted by the company.

1.14 Upon a request in writing from a customer, the company shall conduct a supplementary hazard and risk analysis specific to a use of a product of the company that is outside the promoted range of uses, and this shall be specific to that use and for that customer only. This shall be considered to be exceptional.

From the above it does not appear to push the packaging supplier down the road of proactively investigating the risks related to THE USERS of their products (uses yes – users no). That said you would like to believe the packaging supplied complied with relevant food contact legislation and that the legislation (migration limits) have been set low enough to be safe for all user groups. Hmmm.

What do others think of packaging hazard analysis inside and outside of BRC Standards?

Regards,
Simon

[hSusan]

From the above it does not appear to push the packaging supplier down the road of proactively investigating the risks related to THE USERS of their products (uses yes – users no).

1.7 The hazard and risk analysis shall consider microbiological, foreign objects and chemical contamination, legality and defects critical to consumer safety. The hazard and risk analysis shall be based on the range of uses of the packaging product promoted by the company.

Hi Simon,
This is very helpful for me as I am unfortunately not conversant with the BRC Packaging standard.

The standard does state to consider Defects critical to *consumer* safety (1.7, above) so I would say that it does attempt to push manufacturers down the road of considering the users of their products?

(I take it you mean "consumers" = USERS, and "packaging customers" = USES? Or is it the other way 'round.. oh dear..am confused now)..

(interestingly..does anyone else find in their work, whether in QMS and food safety, that we don't recognise particularly well when we have several customers..ie. our direct customers, but also our customers' customers .. hence
- the packaging manufacturer has their food manufacter as a customer, but they also serve the food consumer who purchases the baby food, or jam or whatever.. (in the case of the baby food..we have mum who buys the food, and the final consumer..the baby!)
- similarly, the pet food manufacturer..who serves the distribution centres of the grocery chains, the grocery chains themselves, the pet owners, and finally, the pets themselves.)

Anyway, my learning from your post Simon..In future I may suggest..when clients have difficulty with applying Codex HACCP to packaging..to consider referring to the Packaging BRC standard for help!

[Charles.C]

Dear Susan,

Not a packaging person but as a general HACCP comment –

From the point of view of use (= usage I think) food HACCP attempts to focus on the hazards as related to the situation existing at the final consumer, eg direct / + cooking consumption, adult/baby consumer, etc for obvious sensitivity type reasons. I presume packaging works in the same way, eg direct / indirect food contact etc.

HACCP is conceptually also intended to consider all aspects of the chain / process leading to the ultimate product usage.This encompasses, for example, pre-requisite GMP functions, transport / distribution chains. However specific presented HACCP plans often take a narrower view – force of circumstances, lack of knowledge / prophetic power as described in yr last paragraph (as you say, the detailed route to the ultimate user (= consumer) can be tortuous )

Actually, I don't quite see why the packaging community (here) appear to be so disparaging of HACCP; after all, it's only another form of risk management (just like auditors)

Rgds / Charles.C

[Simon]

This is very helpful for me as I am unfortunately not conversant with the BRC Packaging standard.

The standard does state to consider Defects critical to *consumer* safety (1.7, above) so I would say that it does attempt to push manufacturers down the road of considering the users of their products?

I think ‘critical defects’ in the BRC Standard refers for example to incorrectly / badly printed ingredients lists on food packaging, or holes in packaging that is meant to provide a barrier to air, water, aroma etc. So something that is contrary to the agreed specification that effects functionality and possibly the safety of the end user (consumer).

(I take it you mean "consumers" = USERS, and "packaging customers" = USES? Or is it the other way 'round.. oh dear..am confused now)..

That’s right.

Anyway, my learning from your post Simon..In future I may suggest..when clients have difficulty with applying Codex HACCP to packaging..to consider referring to the Packaging BRC standard for help!

Although developed in Britain the standard is used all over the world and it really is a very useful standard.

@Charles

From the point of view of use (= usage I think) food HACCP attempts to focus on the hazards as related to the situation existing at the final consumer, eg direct / + cooking consumption, adult/baby consumer, etc for obvious sensitivity type reasons. I presume packaging works in the same way, eg direct / indirect food contact etc.

It does.

Actually, I don't quite see why the packaging community (here) appear to be so disparaging of HACCP; after all, it's only another form of risk management (just like auditors)

I can’t think of a better or more relevant methodology than HACCP for packaging.

Regards,
Simon

[hSusan]

From the point of view of use (= usage I think) food HACCP attempts to focus on the hazards as related to the situation existing at the final consumer, eg direct / + cooking consumption, adult/baby consumer, etc for obvious sensitivity type reasons. I presume packaging works in the same way, eg direct / indirect food contact etc.

Indeed.. that is the intent..however in my experience, packaging companies struggle with implementing HACCP in the wholistic way that the food companies do. I think that the root cause is that the packaging companies don't have the final consumers squarely in their sights..nor the finished food product. It seems that they mostly see their packaging product (film, closures etc) as the object of the HACCP study.

You can see how that can lead to myopia.. limiting the hazards to your standard contamination hazards. How would they recognise an allergen hazard in their print version controls? Or, the criticality of the ingredients panel legibility (or nutrition panel legibility) versus the other panels (such as the product front panels - marketing information - ie. quality vs. food safety).

The most useful approach I have found so far, to help clients see what I mean, is to ask them to put their product together with the food..and imagine it presented to the final customers and consumers. (As part of the PD&IU step). At that point the lights seem to come on a little bit..

But I think the BRC Packaging standard is also a more useful tool in this regard. I have been approaching it from the 'HACCP methodology' direction (less specific)..but the standard simply, clearly lays out the objectives I had been trying to achieve from this - that companies not only consider the usual suspects (microbiological, foreign objects and chemical contamination), but also, "legality and defects critical to consumer safety".

Actually, I don't quite see why the packaging community (here) appear to be so disparaging of HACCP; after all, it's only another form of risk management (just like auditors)

Quite agree..(both Charles and Simon) - to me the key issue is that packaging companies find HACCP difficult to apply to packaging.. my guess - 2 reasons:
1. Don't know how to apply HACCP to packaging (myopia above)
2. Their technical people are not necessarily food people - they are packaging people who have been given HACCP training and asked to develop the HACCP programme.

At least it seems that way here in Australia - in my limited experience. The rest of the world may be more advanced (would not be surprising ) I would be interested to hear from those who deal with packaging suppliers, as well as packaging suppliers, and those who audit packaging suppliers?

[Charles.C]

Dear Susan,



Sorry, rather missed yr initial point as per yr last elegant rephrasing .
The silence response so far suggests to me that most packaging manufacturers offload aspects as being presently discussed aqap onto the next (eg food product content) team.

Actually, with respect to the BRC packaging standard, previous threads suggest that some of yr question is covered by the existence in the standard of a preliminary "scope" section plus various "risk categories" although the latter seem much more restricted in depth compared to features like which you refer. No doubt Simon is much more clued up on this than I and will correct me if I'm wrong (again).

Nonetheless, I totally concur with the principle of yr idea. I presume you hv seen the sample packaging HACCP plan in the docs exchange which noticeably limits its scope to the directly related process factors. Further extension would certainly produce some head scratching and increased telephone bills I suspect. Perhaps not a bad thing. There are clearly plenty of opportunities for implementation since one of the most frequent reasons for recall of products in UK (my visual estimate in newsgirl) seems to be due to omitting allergen warnings on packaging.

Rgds / Charles.C

[Simon]

But I think the BRC Packaging standard is also a more useful tool in this regard. I have been approaching it from the 'HACCP methodology' direction (less specific)..but the standard simply, clearly lays out the objectives I had been trying to achieve from this - that companies not only consider the usual suspects (microbiological, foreign objects and chemical contamination), but also, "legality and defects critical to consumer safety".

Having seen the BRC packaging Standard I think you'll agree the requirements lead the user down the path of a holistic HACCP study outside of the narrow scope of contamination. I agree it has been difficult for packaging people to grasp the concept of HACCP for their processes, but it has been around for more than a decade now, first coming from customer requirements following the UK Food Safety Act 1990 and further by the BRC Packaging Standard. It's pretty common and quite sophisticated in the UK now. I would guess the UK is further down the line than any other country in the world and I know that for a fact when comparing to the US and the rest of Europe.

There are clearly plenty of opportunities for implementation since one of the most frequent reasons for recall of products in UK (my visual estimate in newsgirl) seems to be due to omitting allergen warnings on packaging.

In one respect I agree Charles. Yes the packaging text (such as ingredients - allergen warnings) must be printed accurately and legibly on the packaging by the packaging company, however, the onus for ensuring the ingredients list and allergen warnings are correct lies squarely with the packaging user. It is they who specify and approve the artwork for their product packaging.

Regards,
Simon

[Cathy]

Hi. I just wanted to add a comment on the limitations of HACCP using the categories of biological, physical and chemical. For USDA regulated folks in the U.S., HACCP is based on part 417 of 9CFR. That section actually lists 10 types of hazards and does not mention the 3 categories we've all come to know (and love). The key to functional HACCP is to use the philosophy - consider the hazards - all of them - and deal with them as needed to ensure safety. Understandably, we tend to get tangled up in our words and categories due to the regulatory and auditing side of life.

[hSusan]

In one respect I agree Charles. Yes the packaging text (such as ingredients - allergen warnings) must be printed accurately and legibly on the packaging by the packaging company, however, the onus for ensuring the ingredients list and allergen warnings are correct lies squarely with the packaging user. It is they who specify and approve the artwork for their product packaging.

Yes..then..once the artwork is specified and approved..where does version control lie (at the packaging manufacturer) - as a general QMS programme only, and entirely outside the scope of the HACCP plan process? or, ..or, ..or,..

[Simon]

Hi. I just wanted to add a comment on the limitations of HACCP using the categories of biological, physical and chemical. For USDA regulated folks in the U.S., HACCP is based on part 417 of 9CFR. That section actually lists 10 types of hazards and does not mention the 3 categories we've all come to know (and love). The key to functional HACCP is to use the philosophy - consider the hazards - all of them - and deal with them as needed to ensure safety. Understandably, we tend to get tangled up in our words and categories due to the regulatory and auditing side of life.

Cathy, I’m interested top know what the 10 types of hazards are and in general more about:

For USDA regulated folks in the U.S., HACCP is based on part 417 of 9CFR…

Maybe you could post a new thread in the HACCP forum rather than get different subjects intertwined in one thread.

Yes..then..once the artwork is specified and approved..where does version control lie (at the packaging manufacturer) - as a general QMS programme only, and entirely outside the scope of the HACCP plan process? or, ..or, ..or,..

Susan, the best way to deal with version control is to not have it. In my experience the best way is to raise a new part code even for a small design change such as text change or special offer promos. It’s a little more work, but it prevents mix-ups with either documentation or printing plates. From experience even with a well-controlled version control system mistakes will happen. This is especially difficult when a customer flip flops from old design to new design and back again on special offer promos.

What do other people do to control printed design versions?

Regards,
Simon

[GMO]

Going back to the original question; I don't think defects aren't covered by the biological, physical, chemical questions. When asking those questions, you're thinking about the hazard, not the cause; a defect in film is a cause potentially of one or more of those hazards. In food manufacturing we also have to think of the hazards caused by failure of a seal which might be "contamination with environmental pathogens such as Salmonellae, E. coli due to failure of the package seal" in that case it depends upon the food but pinhole failure of the seal would not in my view be a significant risk even in ready to eat products unless there was an MAP or VP for food safety reasons; that is because there is plenty of packaging out there which is not air tight! (Next time you're in a supermarket look at any chilled items wrapped in board packaging.) A larger failure of the seal may make it easier for malicious contamination of course which needs consideration.

[Simon]

Going back to the original question; I don't think defects aren't covered by the biological, physical, chemical questions. When asking those questions, you're thinking about the hazard, not the cause; a defect in film is a cause potentially of one or more of those hazards.

What would you say about a print defect such as missing print or print that was poorly printed out of register making it unreadable. That kind of defect cause does not result in chemical, biological or physical effect does it? Or maybe it does.

Simon

[GMO]

It depends upon what the print defect is but Simon don't forget, unless it causes a food safety hazard, you should not be considering it as part of HACCP! It could cause an allergen not to be declared (chemical hazard), shelf life not to be adhered to (biological hazard). The poor printing is the cause of the hazard and not the hazard itself. It's like saying "chilling" is the hazard for high risk, ready to eat chilled foods. It's not. The hazard is the growth of pathogenic bacteria such as Listeria monocytogenes due to the product not being chilled or failure of the chiller system etc. That's still a biological hazard not an engineering one!

[Simon]

It depends upon what the print defect is but Simon don't forget, unless it causes a food safety hazard, you should not be considering it as part of HACCP! It could cause an allergen not to be declared (chemical hazard), shelf life not to be adhered to (biological hazard). The poor printing is the cause of the hazard and not the hazard itself. It's like saying "chilling" is the hazard for high risk, ready to eat chilled foods. It's not. The hazard is the growth of pathogenic bacteria such as Listeria monocytogenes due to the product not being chilled or failure of the chiller system etc. That's still a biological hazard not an engineering one!

I think we are both in agreement though that print faults are critical defects that can affect consumer safety.

BTW until you mentioned you were a lady I would have bet my life that you were a man, maybe it's the avatar, but more probably the tone of your posts. I don't know if that's sexist of me to make such an assumption, if it is not meant to cause any offence. In fact it raises a bigger issue on forums and such with usernames that are sexless why/how do I always make a subconscious judgement to the member’s sex. Hmmm.

Regards,
Simon

[GMO]

I know - I realised earlier on that several members thought I was male. I'm just an assertive female Muppets fan.