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HACCP has been used by the food industry for a number of years to ensure the safety of food products.  It was first used by NASA to ensure that food for astronauts in space was fit for use. Since that time, it has been used by a number of non-food applications including packaging.

By Alan Campbell, packaging and manufacturing specialist, Campden BRI

The use of HACCP is regulated within the EU for food use (EU/852/2004), but it is not a legal requirement for use in any packaging or food contact applications. The requirements for Hazard Analysis or HACCP are being driven from customers through retailer standards as defined in one of the GFSI (Global Food Safety Initiative) Standards.

It is worth noting that the EU packaging regulations do make reference to food safety with Article 3 of EU 1935/2004. It states that materials and articles “shall be manufactured in compliance with good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer their constituents to food in quantities” which could endanger health, cause changes in food composition, or deteriorate its organoleptic characteristics. It also stipulates, “The labelling, advertising and presentation of a material or article shall not mislead the consumers.”

Other EU Regulations to consider are: EU regulation 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food (GMP); and EU regulation 10/2011 on plastic materials and articles intended to come into contact with food (Plastics) .

Hazard analysis for packaging

HACCP for packaging can be described as “A system which identifies, evaluates, and controls hazards which are significant for product safety”. The Codex Alimentarius lists the principles for HACCP as:

  1. Identify potential hazards and measures for their control,
  2. Determine critical control points (CCP),
  3. Establish critical limits which must be met to ensure each CCP is under control,
  4. Establish a monitoring system,
  5. Establish the corrective action to be taken when monitoring indicates that a CCP is not under control,
  6. Establish verification procedures to confirm that the HACCP system is working effectively,
  7. Establish documentation for procedures and records.

It can be seen that the GFSI document incorporates these principles in the requirements listed below.

The standard requires that the elements of the organization’s Food Safety Management System for packaging materials be documented, implemented, maintained and continually improved.

The management system shall:

a)    identify the processes needed for the effects of packaging of Food Safety Management system,

b)    determine the sequence and interaction of these processes and procedures,

c)    determine criteria and methods required to ensure the effective operation and control of these processes,

d)    ensure the availability of information necessary to support the operation and monitoring of these processes,

e)    measure, monitor and analyze these processes and implement actions necessary to achieve planned results and continual improvement,

f)     ensure that packaging used to impart or provide a functional effect on food such as shelf life extension shall be effective within its own specified criteria , where known,

g)    validate packaging design and development to ensure food safe and legal manufacture.

The document goes on to state standard requirements, including having in place a Hazard and Risk Management system with pre-requisite programs. This may be a HACCP-based system or another Hazard and Risk Management system that covers the Codex Alimentarius HACCP principles. The scope of the Hazard and Risk Management system covers all processes of the materials encompassed within the standard to ensure that none of their components parts or the whole material could compromise food safety.

Good manufacturing/hygienic practices

Additionally before starting the Hazard Analysis the packaging manufacturing facility needs to implement the prerequisite program of good manufacturing practices (GMP) and good hygienic practices (GMP). The latest EU guidance documents indicate that, under Prerequisite Programs (PRP), it is necessary to consider both GMP and GHP. A good reference guide is listed in within Codex Alimentarius:

  • Codex General Principles of Food Hygiene
  • Appropriate Codex Codes of Practice
  • Appropriate Food Safety Requirements e.g. Legislation.

Currently, there are four standards benchmarked for use against the GFSI standard: IFS PacSecure (Version 1) - October 2012; FSSC Packaging - ISO/TS 22002-4 2013; SQF Code Level 2 (edition 7.2) – July 2014; and BRC/IoP Global Standard (V5) – July 2015.

The IFS PacSecure document gives some good information related to the prerequisite program. Each requires proper documentation of the program elements and supporting information including, but not limited to: standard operating procedures, forms, checklists, corrective action reports, and food safety program reassessment.

The BRC/IoP Document provides information to be considered as:

Product Description

A full description of the product must be developed, which includes all relevant information on product safety, quality and integrity. As a guide, this may include information on: composition (e.g. raw materials, inks, varnishes, coatings and other print chemicals), origin of raw materials, including use of recycled materials, and the intended useof the packaging materials and defined restrictions on use (for example, direct contact with food or other hygiene-sensitive products, or the physical or chemical conditions).

Hazard Identification

Hazard is defined as “A biological, chemical or physical agent in, or condition of, packaging material with the potential to cause an adverse health effect.”

Hazard Analysis is the process of collecting and evaluating information on hazards and conditions leading to their presence to decide which are significant for packaging material safety and therefore should be addressed in the HACCP plan.

You can read more in our print magazine European Baker & Biscuit (March/April 2017)!

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