An addendum to previous post.
You asked for examples. I hope the semi-monolog below is not too off-topic while wait for any packaging manufacturers’ comments.
One example i have is the following: we produce packaging for a customer who packs high risk food like meat
Actually, as you probably know, meat is not intrinsically a high risk product, although, for example, RTE presentations probably will be. The usage situation may also influence the consequence of yr example from a HACCP
point of view, eg if the meat is packed in an inner plastic bag and so protected from direct contamination or not. If not, I personally hv some agreement to yr comments.
I can give 2 analogous operational examples for consideration from my own experience primarily as a packaging user –
1. Defective plastic bags
Plastic used to enclose deep-frozen meat has to accept temps of <-30degC. Inferior raw plastic material may eventually go brittle and crack, maybe after 1day or 1month thereby exposing the contents to “some” degree of contamination risk.. IMO, this (and other potentially similar defects) should require the original “receiving plastic ingredient step” to be an automatic CCP
for the bag manufacturer. Such was the case in early traditional HACCP
. The consequence was that many CCPs
prevailed in HACCP
plans prompting the use of (pseudo-generic) pre-requisite stages which incorporated such preliminary steps (similar manouevrings occurred to GMP sanitation factors).
It is obviously debatable at what level an implanted routine prerequisite function should change into a full CCP
due to personal bad experiences. The original proposers stressed that every HACCP
plan was inevitably unique to the implementer and that pre-requisites could only be guidelines. Regardless the officially published formats immediately became natural “validations”. Codex stopped issuing “generics” several years ago due to such issues. I hv had many lengthy arguments with auditors over such questions because I don’t like pre-requisites very much since I feel they tend to dilute the HACCP
power. However I accept they effectively minimise the text volume and if used properly help to focus the plan on the most significant parameters.
2. Defective retail boxes
Some types of cardboard boxes may hv coatings. The coating is not applied to end flaps due possible interference with the efficiency of final glueing / closure leading to boxes springing open within cold storage and again leading to risk of contamination. Nonetheless, box suppliers sometimes do lose control over the positioning of such coating. The rest of the story mirrors example No.1
Obviously, immediate steps are taken to correct such packaging failures but re-occurrences may still occur. The advantage of using pre-requisites is that solving such issues is potentially isolated to the preliminary stages. This is not necessarily wrong if one allocates due importance to the pre-requisites however the tendency for Plan users is to be somewhat “blasé” over the pre-requisite areas. It is possible there should be some rule that a repetition of more than X incidents of a pre-requisite failure automatically leads to changes in the main HACCP
plan text regardless of the perceived risk status ??
A third example of more current interest popularity is regarding allergen warnings on printed packaging. Not a packaging defect per se but certainly consumer safety related. Maybe you saw the thread already including the packaging HACCP
example plan – http://www.ifsqn.com...wtopic=7233&hl=
(main link still seems working)
There is also a lot of vaguely relevant input from packaging posters in this threadhttp://www.ifsqn.com...wtopic=1135&hl=
(laura’s link is broken, I can replace it [somewhere] if u are interested) (added - now added the links in above quoted original thread, see my post ca.09022008, hopefully correct)
(@Simon, begins to look sadly like there are not so few losses over this bug)
Hope the above not too meandering compared to yr superby minimalist posted query.
Rgds / Charles.C
added - although I hv remarked above on the well-known fact that every HACCP
plan is personalised, it is important to remember that the classification of "significance" in hazards is inevitably biased towards existing statistical/epidemiological data since this is validatory. This means that yr inclusion of CCPs
whatever based on personal bad experiences/opinions without having additional xreferences to similar occurences tends to be automatically picked up by auditors IMEX who are naturally hoping for a minimum of argumentative CCPs
to have to scrutinise within their limited working day. Ironically, omission of favourite auditor CCPs
, eg metal detectors, may produce a similar negative response.