Is Packaging Raw Material COA/COC an oPRP or a CCP?

 We are on the process of revising our HACCP Plan for the manufacture of Rigid Plastic Packaging with In mold labels and one of our issue is that the label suppliers (abroad - from Taiwan) having a hard time on providing us a COA/COC for their deliveries of IML. I'm planning to include this in our HACCP Plan is there anyone who can help me identify if this is an oPRP /CCP.

 We are on the process of revising our HACCP Plan for the manufacture of Rigid Plastic Packaging with In mold labels and one of our issue is that the label suppliers (abroad - from Taiwan) having a hard time on providing us a COA/COC for their deliveries of IML. I'm planning to include this in our HACCP Plan is there anyone who can help me identify if this is an oPRP /CCP.

Dear edgar besarba,

I have no idea what “IML” is but if the packaging ISO 22000 standard / associated ISO 22002 are  analogous to those for food,  the control of  incoming  product components is typically handled by a PRP.

Rgds / Charles.C

Hi,

I have worked with IML for the manufacture of ice c  ream tubs and lids.

we had 3 hazards to do with label supply:- 

1. Artwork control. Was it the right information on the label/current version of nutrition etc.

This was a OPR. Artwork/cromalin was approved by us before printing and a sample of each print run was checked (either by goods in check QC sample or the samples were posted to us in advance of delivery for checking by QC) The supplier needs to have good systems in place. This was established by audit/questionnaire and evaluation of their procedures (by post)

2. Legibility. Is the print readable. Is it smudged missing etc. through out the run. This has to be controlled by the printer on the label. So you need to be aware of their in line print checks and be confident in them. Again by evaluation of the suppliers systems (questionnaire covering that specifically)

3. The label supplier often did composite runs. (one sheet with several designs printed on it). They would then cut the labels from the web and segregate the various designs. They need to control the segregation to prevent the various flavors/ designs /allergen containing labels to prevent the customer from receiving a box of mixed labels which would then all get molded to lid and sold to the co-packer with a rogue label. Obviously the hazard is that, for example, a vanilla label is in the box of nutty labels and a nut ice cream gets labelled with a vanilla tub /lid. Again supplier evaluation, BUT we also had a vision system/camera on our line which scanned every label down our line and alarmed/rejected any rogues. Again OPR but there would be a simple recorded acknowledgment that the system was in place and working, with a challenge tests recorded every shift/run. 

Basically if you can not get what you want from your supplier put in your own controls. You may be best to have them anyway. The team risk Assessment will guide you to the needs. Our camera system was a good send .We had lots of rogues delivered. Some supplier have a camera on their lines too.

All were OPRs. I've babbled on so much I am not sure what the question was now! Hope this is useful.

Sharon

Dear Sharon / E-B,

At least I now know what IML is. Thank you.

And further thanks to Sharon for the interesting comments.

But regarding CCP/OPRP, i have to maintain my original opinion inasmuch as i deduce we are still talking about external inputs to the actual manufacturing process. On the other hand, if the labels are part of the total manufacturing process as being analysed, my opinions might change. Unfortunately no flowchart is presented by OP.

It sounds like Sharon utilised a different decision procedure as compared to use of PASS220 / ISO 22002-1?. One outcome of such approaches can sometimes be an abundancy of OPRPs (and work?). Ironically, such an aspect was a well-known (CCP) criticism of early HACCP methodologies (which also struggled regarding the allocation between PRPs and CCPs).  I previously met a similar (input) conundrum in the detailed hazard analysis for yoghurt manufacture (available on this forum) and partially resisted the PAS220 format (my logic is presented at the relevant yoghurt posts here). However, after further experiences, I would probably now choose to revise that evaluation into all PRPs as per PAS220.

Nonetheless, my opinion is undeniably arguable since the IFSQN package available on this site has a detailed menu of OPRPs after utilising a slightly different (I think) interpretation of the standard.

Would be interesting to get more poster comments but I suspect use of this ISO standard for packaging is, overall, rare.

Rgds / Charles.C

PS i presume that E-B is familiar with the (IT-published) detailed, model hazard -CCP analysis (using traditional HACCP) for rigid plastic packaging whch is linked in a current parallel thread here.?

 We are on the process of revising our HACCP Plan for the manufacture of Rigid Plastic Packaging with In mold labels and one of our issue is that the label suppliers (abroad - from Taiwan) having a hard time on providing us a COA/COC for their deliveries of IML. I'm planning to include this in our HACCP Plan is there anyone who can help me identify if this is an oPRP /CCP.

Hi Edgar,

My initial thoughts are similar to Charles.

PAS 223:2011 Prerequisite programmes and design requirements for food safety in the manufacture and provision of food packaging provides guidance for this in Section 9.3 Incoming Raw Materials.

'Raw materials shall be inspected, tested or covered by a CoA/CoC to verify conformance........'

So as a minimum it should be a prerequisite. In the same section of PAS 223 there is a note:

'The inspection frequency and scope may be based on the hazard presented and the hazard assessment of the specific suppliers'

If this control is for a significant hazard then you need to assess as per ISO 22000 7.4.4 Selection and assessment of control measures where you consider a) to g) (which include the effect on the hazard, severity in event of failure, ability to monitor etc). Based on this assessment you will ascertain whether the hazard is controlled by an OPRP or is part of the HACCP plan.

Regards,

Tony

OPRP

OPRP

Dear Prasant,

Could you justify yr decision ?

Rgds / Charles.C