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HACCP for Food Packaging
Processes
Hazard Analysis Critical Control Point (HACCP) is the recognised method
for conducting a food safety hazard analysis and the methodology provides
a useful framework for conducting a hazard analysis in a food packaging
context.
On this page we provide you with the information and practical advice
you need to implement a Hazard Analysis Critical Control Point (HACCP)
system in your organisation that will meet the BRC Global Standard - Food
Packaging requirement for the adoption of a formal hazard and risk management
system.
HACCP
puts man in space
A HACCP system is a preventative approach to controlling
food safety. HACCP moves away from reliance on end product testing to
a more proactive, preventative approach of controlling potential hazards.
Although HACCP is a relatively new concept to the food
packaging industry, it has it's roots way back in the sixties. The first
incarnation of HACCP was developed by the Pillsbury
Corporation and the National
Aeronautics and Space Administration (NASA), to ensure food safety
for the first manned space missions.
Since then, it has been widely adopted by national and international organisations,
and the modern HACCP system and guidelines for its application were defined
by the Codex
Alimentarius Commission in the Codex Alimentarius Code of Practice.
Ascent of
HACCP
The ascent of HACCP has been rapid, mainly because
of the increase in the reported cases of serious food poisoning and the
introduction of The
Food Safety Act 1990 and The
Food Safety (General Food Hygiene) Regulations 1995 (EU Food Safety
Directive 93/43/EEC), which requires a food business to carry out a hazard
analysis.
Although there is no legal requirement for food packaging
manufacturers to carry out a hazard analysis, in recent years it has been
a strong customer requirement and the adoption of a formal Hazard Analysis
System is now an explicit requirement of BRC
Global Standard - Food Packaging.
| Benefits
of HACCP |
| • |
A preventative approach to food
packaging safety |
| • |
Can help identify process improvements |
| • |
Reduces the need for, and the cost of end
product testing |
| • |
Is complementary to quality management systems
such as ISO 9000 |
| • |
Provides evidence of due diligence |
| • |
Reduces the likelihood of product recall
& adverse publicity |
| • |
Enhances customer satisfaction / reduces
dissatisfaction |
| • |
Facilitates better understanding of food
packaging safety issues throughout the organisation |
| • |
Improves staff performance through the promotion
of team spirit |
| • |
Improves staff morale and motivation through
a cleaner working environment |
| • |
Helps maintain compliance to the BRC Global
Standard - Food Packaging |
HACCP
principles
The standard approach to HACCP is that specified
by the Codex Alimentarius, 1997, and follows 7 basic principles:
| 1. |
Conduct a hazard analysis |
| 2. |
Determine the critical control points |
| 3. |
Establish critical limits |
| 4. |
Establish a system to monitor control of the CCP |
| 5. |
Establish the corrective action to be taken when monitoring indicates
that a particular CCP is not under control |
| 6. |
Establish procedures for verification to confirm that the HACCP
system is under control |
| 7. |
Establish documentation concerning all procedures and records appropriate
to these principles and their application |
The puzzle
for packaging
HACCP was developed for the food industry and there
are no guidelines for implementing HACCP within a food packaging context.
The puzzle for packaging therefore has been trying to apply the Codex
Alimentarius principles to food packaging and this has been the cause
of endless frustration for the packaging quality professional. HACCP is
a difficult enough system to implement when the guidelines are wholly
relevant!
In general it is recognised that Critical Control Points
(CCP's) as encountered in food companies, do not exist in food packaging.
For example, if a food needs to be cooked for 30 minutes at 150°C
in order to destroy any dangerous bacteria that may be present, then this
is obviously a Critical Control Point and time and temperature are the
control parameters that must be monitored. In my experience of carrying
out HACCP studies on food packaging processes; I have found it extremely
difficult (almost impossible) to identify CCP's (in their true form),
and this has always created healthy debate with food safety auditors during
technical audits. Most of the hazards that can be identified in a food
packaging operation are of a generic nature and could occur at any stage
of the process e.g. blades, glass, pests, poor personnel hygiene etc.
These types of hazards are controlled by what are commonly referred to
as 'prerequisite programmes' e.g. the standard operating procedures and
basic environmental conditions that are necessary
for safe food packaging production, and one would expect to find
these in any comprehensive food packaging Good Manufacturing Practice
(GMP) / Good Hygiene Practice (GHP) system.
Prerequisite programme
Requirements for what should be included in a
prerequisite programme are widely
specified for food operations.
Fortunately the criteria for the 'prerequisite programme' for food packaging
manufacture is now very straightforward.
It is the requirement for:
| • |
a documented Technical Management
System |
| • |
the control of factory standards, products,
processes and personnel |
as specified in sections 4, 5,
6 and 7 of BRC Global Standard - Food Packaging.
You may well find that the HACCP study does not identify any additional
required control measures, but the practice of carrying out a hazard analysis
may identify improvements, or exemptions against specific clauses
of the standard. The HACCP study also provides for a greater understanding
of the process and demonstrates that 'all risks' have been considered
and that hygiene is under control.
HACCP study
guide
The BRC Global Standard - Food Packaging requires
a formal hazard analysis of the production process to be undertaken considering
foreign objects, chemical and microbiological contamination as well as
packaging defects critical to consumer safety. The following can be used
as a guide for carrying out a HACCP study:
If you are developing a food packaging technical system to
meet the requirements of the BRC Global Standard - Food Packaging sign
up for the discussion
forum to download free document templates including an example HACCP
study, procedures and forms.
1. Assemble the HACCP team
The team should be multidisciplinary and consist of people
who know the process. Building your team from a wide spectrum of manufacturing
personnel, and allowing them to identify the hazards within their
process, facilitates greater understanding, and they will be much
more likely to take ownership of solutions, controls and procedures. |
2. Train the team
It's commonsense but all team members should have at least a basic
understanding of HACCP principles and methods. |
| 3. Outline the Terms of Reference
This is where the documentation of the HACCP system starts
- The HACCP Plan. Begin by outlining the 'Terms
of Reference' of the HACCP Study, e.g.
| • |
The HACCP study covers all products manufactured at AAA factory. |
| • |
The HACCP study covers the production process from raw material
source to delivery of finished product to the customer. |
| • |
For each process step all potential hazards to consumer safety
and product integrity have been identified and appropriate control
measures established to minimise their risk. |
| • |
The hazards considered by the study are foreign objects, chemical,
microbiological and packaging defects critical to consumer safety. |
| • |
The HACCP study has been carried out by the following team:
Mr Black- Technical Manager
Mr Pink - Quality Manager
Mrs Brown - Warehouse Manager
Mr Red - Print Manager
Mrs Blue - Conversion Manager
Mr Green - Engineering Manager |
| • |
The HACCP Team will review the HACCP Study annually and following
significant changes to the process. |
It's good practice to produce the terms of reference before
commencing the HACCP Study proper as this will help to focus the minds
of team members for the task ahead. |
4. Describe the product
Describe the product and product composition e.g. materials,
coatings etc. Also detail any shelf-life and storage conditions that
apply. |
5. Identify the products intended use
Describe the users and uses of the product. e.g. Product
AAA is used by customers for direct contact packaging of food, pharmaceutical
and tobacco products. Product AAA provides a tamper evident seal in
order to protect and preserve customers products. |
6. Construct the Process Flow Diagram
Draw a simple 'flow chart' of the main process steps. Consider
process steps not physically within the operation e.g. raw material
sourcing and delivery of finished product to the customer. |
7. Validate the Process Flow Diagram
Ensure that the Process Flow Diagram is accurate and is validated
by all team members and other relevant personnel. |
8. List all Potential Hazards Associated
with Each Process Step
Carry out a detailed analysis of each process step listing
all hazards that could reasonably be expected to occur. |
| 9. Conduct the hazard analysis
Analyse each of the identified hazards. The hazard analysis
should follow general principles for quantitative risk assessment,
although the decision as to the likelihood and severity of each
hazard is rather subjective. Historical incident/complaint data may be useful for
clarifying the likelihood of the risk occurring.
(L) = the Likelihood of
the hazard occurring
(S) = the Severity of the
outcome
| (L) Likelihood |
(S) Severity |
| 3 High |
3 High |
| 2 Medium |
2 Medium |
| 1 Low |
1 Low |
L X S = R
(R) = the Risk Level
for the specified hazard
Risk Level
1-3 Low risk (establish control
measures where appropriate)
4-6 Medium risk (establish control measures)
7-9 High risk (Critical Control Point)
|
|
10. Consider Control Measures
The HACCP team must consider what control measures, if any,
exist which can be applied for each hazard. More than one control
measure may be required to control a specific hazard(s) and more than
one hazard may be controlled by a specific control measure. |
| 11. Establish Documentation
Because we have attributed a "numerical risk level"
for each of the hazards we can determine both the priority for addressing
the hazards and the level of control and monitoring required.
Obviously start by addressing the hazards with the highest risk
level and develop appropriate process control and monitoring procedures
and the supporting documents and records.
The vast majority of the hazards will be generic (not process step
specific) and should be controllable by the provisions of the BRC
Global Standard - Food Packaging (the prerequisite programme).
|
| 12. Critical Control Points
Where Critical Control is required the following range of measures
should be established for the CCP:
| 1. |
Critical limits |
| 2. |
Monitoring system |
| 3. |
Corrective action |
| 4. |
Documentation and record keeping |
| 5. |
Verification procedures |
e.g. To try and get a handle on this it may serve to give an example:
Let's say that the hazard analysis identified that the 'level of
risk' of blade contamination following a tool change by an engineer
was high, and the HACCP Team determined this to be a CCP.
We could implement a system whereby following every tool change
the engineer was required to clear the machine of all extraneous
matter and sign off the machine as 'safe for production''. The measures
could then be:
| 1. |
The clear-down must be completed by the engineer
100%. |
| 2. |
Effective completion of the clear-down
must be verified by a supervisor before production can commence.
|
| 3. |
If production had commenced and the clear-down has not been
completed then internal reject/product recall procedures should
be initiated. |
| 4. |
The documentation would be a checklist detailing the requirements
of the 'clear-down' and provisions for the engineer/supervisor
sign off, machine number, production order number etc. |
| 5. |
Regular routine audits of completed checklists should be carried
out. |
|
13. HACCP Review
All controls required by the hazard analysis should be regularly
reviewed, verified and validated to ensure that they are functioning
effectively and to ensure that they are still up to date and reflect
current knowledge. This should be done both through internal auditing
and by the HACCP Team who should carry out a full review of the HACCP
Study annually and following significant changes to the process.
Include a supplementary sheet in
the HACCP Plan for recording the dates of reviews and the details
of any changes to the HACCP plan. |
14. HACCP
Training
To ensure effective implementation of HACCP it is essential that employees
understand the basic principles of the HACCP system and their role
within it. They must be trained to identify potential contaminants
and they must be shown how to prevent them through training in relevant
control measures and procedures. |
15. Exemptions to provisions of the standard
The hazard analysis may show that some aspects of the production
process can be exempted from some of the provisions of sections 5,
6, 7 and 8 of the BRC Global Standard - Food Packaging e.g. in a low
risk area such as a finished goods warehouse, where all product is
covered and there is no manual handling. It may be that the hazard
analysis confirms that 'hand washing' is not a required control.
To be accepted by the Certification
Body an exemption must be clearly identified by the hazard analysis
and the reasoning documented in the HACCP Plan. |
Further
reading
Hygiene
Audit and HACCP Training for Packaging Manufacturers
by Dagmar Engel
A book written specifically for packaging! Now Available.
Links
Foodlink
If there can be such a thing as a magical 'food safety' web site then
this is it!
Food Standards Agency
A wealth of information from the independent food safety watchdog.
Food Safety Today
The Food Safety Today site is a regular alerting and information service
from the Leatherhead Food International in the UK, one of the world’s
leading research, information and training centres for the food and drinks
industry.
Wait
- grab yourself a coffee first!
This comprehensive list of food safety links is reproduced from the Appendix
of Dr Stephen Forsythe's book, The Microbiology of Safe Food.
| Jargon
review |
| Control (verb) |
To take all necessary actions to ensure and maintain
compliance with criteria established in the HACCP Plan. |
| Control (noun) |
The state wherein correct procedures are being
followed and criteria are being met. |
| Control measure |
Any action and activity that can be used to prevent
or eliminate a food safety hazard or reduce it to an acceptable level. |
| Corrective action |
Any action to be taken when the results of monitoring
at the CCP indicate a loss of control. |
| Critical Control Point (CCP) |
A step in the process at which control can be
applied and is essential to prevent or eliminate a food safety hazard
or reduce it to an acceptable level. |
| Critical limit |
A criterion which separates acceptability from
unacceptability. |
| Deviation |
Failure to meet a critical limit. |
| Flow diagram |
A systematic representation of the sequence of
steps or operations used in the production or manufacture of a particular
food packaging item. |
| HACCP |
Hazard Analysis Critical Control Point - a system
which identifies, evaluates, and controls hazards which are significant
for food safety. |
| HACCP plan |
A document prepared in accordance with the principles
of HACCP to ensure control of hazards which are significant for food
safety in the segment of the food chain under consideration. |
| Hazard |
A foreign object, chemical or microbiological
agent with the potential to cause an adverse health effect. |
| Hazard analysis |
The process of collecting and evaluating information
on hazards and conditions leading to their presence to decide which
are significant for food safety and therefore should be addressed
in the HACCP plan. |
| Monitor |
The act of conducting a planned sequence of
observations or measurements of control parameters to assess whether
a CCP is under control. |
| Step |
A Point, procedure operation or stage in the production
process from raw material source to delivery of finished product to
the customer. |
| Validation |
Obtaining evidence that the elements of the
HACCP plan are effective. |
| Verification |
The application of methods, procedures, tests
and other evaluations, in addition to monitoring to determine compliance
with the HACCP plan. |
| Adapted from Codex Alimentarius
Food Hygiene Basic Texts 1997. |
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