Risk assesment in packaging

Recently I had a little argue with HACCP auditor in meat production area, because HACCP team did not identified risk from wrong packaging. (example. they produced pork chops, but human/system mistake gave them a Packaging for chicken chops (of course that never happened, but suggestion was to identify that as a possibility)). What do you think, could this be an hazard, and what kind of hazard would it be? physical, chemical or microbiological. I understand that this could cause confusion for customer, but...

Recently I had a little argue with HACCP auditor in meat production area, because HACCP team did not identified risk from wrong packaging. (example. they produced pork chops, but human/system mistake gave them a Packaging for chicken chops (of course that never happened, but suggestion was to identify that as a possibility)). What do you think, could this be an hazard, and what kind of hazard would it be? physical, chemical or microbiological. I understand that this could cause confusion for customer, but...

IMO wrong labelling or incomplete/missing ingredients on labelling or illegible information on packaging or labels because of say printing defects can certainly be a hazard to the consumer and should be considered. Whether it is chemical, physical, microbiological or some other new fourth dimension I don’t know. Does codex deal with these types of hazards? Maybe some of the HACCP experts can help out.

Regards
Simon

Dear vitez,

Original HACCP plans typically included “mis-labelling” as an automatic CCP (together with many other parameters). Subsequently the pragmatic risk assessment approach / use of PRPs significantly reduced such lists.
I was driven to remove “mislabelling” as a general CCP by successive auditor attacks. Was only tolerated where a significant health hazard could be demonstrated, eg failure to declare allergen possibilities, absence of “must be cooked” banners on raw products.

Can the chicken / pork confusion fit such a scenario? Depending on the possible consumer, maybe ?

Rgds / Charles.C

Hi Vitez,

Basically the packaging materials for fresh meat products be it chicken, deer, pork or cow are the same, the exception is deep freeze products were there is no barrier needed for o2.
Using a deep freeze bag for a fresh meat application leads to meat that turns green. The barrier bag into deep freeze could lead to leakers as the bags become more stiffer than is good for them and they can become damaged in the process of moving and H2O is lost from the meat.
Meat with bones requires in general thicker packaging materials, some mixing here could lead to punctures of the packaging material with negative effects for the product.
Producers of packaging materials need to identify the risk of mixing and should use preventive measures, labeling and or color coding.
Be sure that the label makes clear the intended use of the product and ask your producer what the risks are.
One other reason to be careful is mixing with packaging materials for cheese packaging, these packaging materials have different barrier properties, so if your packaging producer sends you the wrong boxes and you do not read the labels properly your meat will turn green.
There are more very remote issues regarding the barrier materials that are used in different packaging materials and your supplier should give you his advice.

I would categorize this as a quality item rather than chemical, biological or physical, risk = low, effects = high, preventively maybe separate storage of different packaging materials?????.

Have a nice day, Okido

Dear All,

Be sure that the label makes clear the intended use of the product and ask your producer what the risks are

and should be considered. Whether it is chemical, physical, microbiological or some other new fourth dimension I don’t know.

Indeed. How about the increasingly popular "regulatory" hazard ?

As an example -

USA -- Animal-rights and Muslim groups say they want a piece of the $10
million that McDonald's has agreed to pay for mislabelling its French fries
as vegetarian.

The fast-food giant announced in May that it would pay the money to
settle a class-action lawsuit brought by three vegetarians in Seattle,
including two Hindus who don't eat meat for religious reasons. McDonald's
used beef flavouring for years while claiming its fries were vegetarian.

http://www.vnv.org.a.....DS SETTLEMENT
(item 20)

Perhaps a "psychological hazard" to health (= biochemical ) ?

In contrast I also found an opinion within a crisis management article which had impressed me up to this rather surprising item IMO. Legally correct in UK ? -

Issues that could cause serious customer dissatisfaction or be misleading such as meat in a vegetarian product need to be considered. Mislabelling would not normally trigger the need for a recall situation unless an allergy issue was involved.

http://www.sefgp.co....lay.aspx?ID=402

Thanks Charles, as ever brilliant demonstration of SRS*.

*Surfing Research Skills

Thanks a lot, you opened me a whole new point of view. This is fantastic.

Thanks a lot, you opened me a whole new point of view. This is fantastic.

Forgive my ignorance, but i would have thought that the risk assessment would need to include labelling an "allergenic" product with a non allergen label. then the severity could be high.

Label beef as pork is more of a "quality"issue... unless your a hindu!

Does agree with most of comments here..think of wrong packaging that can lead to misunderstand about food that effect to Hazard exp..cook/uncook..allergen/non allergen..GM/non GM that could consider "RISK" so its should consider case by case.. :)

IMO.. you have state what type of your packaging.. in my company we state that we use multilayer paper bag that contain 3 layer paper kraft and 1 layer LLDPE plastic.. and our supplier give us the statement for plastic that they use only LLDPE..

The statement from the supplier is objective evident that we control our raw material (including packaging material) that no hazard from packaging material...

As I known, some plastic have properties that no suitable for some food because of migration properties of monomer... so Supplier assurance is important factor in HACCP to avoid any hazard from packaging material.

<br />Recently I had a little argue with HACCP auditor in meat production area, because HACCP team did not identified risk from wrong packaging. (example. they produced pork chops, but human/system mistake gave them a Packaging for chicken chops (of course that never happened, but suggestion was to identify that as a possibility)). What do you think, could this be an hazard, and what kind of hazard would it be? physical, chemical or microbiological. I understand that this could cause confusion for customer, but...<br />

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Wrong for the auditor: Principle 1 states that the Food Safety team has to “list all of the hazards that may be REASONABLY expected to occur at each step according to the scope”. And the auditor does not have the authority to affirm that kind of judgments because he/she is not a member of your Food Safety Team; it could be only an OBSERVATION but never a non conformity. Wrong packaging could be a problem only when allergens and/or others sensitive ingredients are involved.

And the auditor does not have the authority to affirm that kind of judgments because he/she is not a member of your Food Safety Team;

An Auditor needs to be technically competent and be capable of identifying potential adverse risk(s) that could impact public health during an audit. It is the duty of the auditor to determine if the FSMS risk assessments were adequately covered and TECHNICALLY correct and justified. Personally, I would be grateful to the auditor for highlighting to my Company that we could face a potential risk of a mix-up in product identity that could lead to a potentially massive product recall....you frequently see these sorts of recall incidents highlighted at the Food Standard Agency.

Wrong packaging could be a problem only when allergens and/or others sensitive ingredients are involved.

I agree and that is why we have unnecessary recalls when end products are matched with with wrong product contact packaging materials. The issue goes beyond "allergens" and I also share the same view as "AS NUR" with regards to potential chemical hazards such as Monomer including Bisphenol A, Semicarbazide, Phtalates, BAGDE, epoxy polyamide etc

Wrong product contact packaging that are not suitable or intended for the end product relative to the process type can dangerously impact the intended end product shelf life including leaching of poisonous chemicals and metabolites into the product while on the display shelf.

here is the literature for packaging contamination... hope can help you

Dear Vitez

I would manage that issue as a PRP

REgards
Esther

I think that PRP is ideal for this type of hazard. But as i said this was problem in a meat factory, so auditor sugested that aditives could be problem when mispackaging, he said that you do not have same aditives in pork sousage or salame as in beef salame, so that can result as a potential hazard. I will get his audit report and share it with you next week.

Thanks for all comments