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[Tflex]

Hello,

 

I've been lurking here for quite a bit and there seems to be a lot of knowledgeable people here. So I hope I can get some advice.

I just started working at a company that prints and laminates flexible packaging. From what I can tell packaging companies usually don't have any CCP's. Well this company has 3, but I have doubts if these should be considered as CCP's.

 

The first CCP is regarding ink when not dried enough will offset to the food contact side. Because ink is not food grade this would be considered a food safety risk. The operator checks the temperature of the dryer with every rol to see if it equals the temperature that was set before the start of the order. There are no agreed values as to what temperature the dryer should be set on. This is completely dependent on the experience of the operator, the order and the speed`of the machine. There's also visual checks on the packaging itself to check for any printing errors, but no specific check for the dryness of the ink. As far as I know with a CCP the product should be measurable with specific tressholds.

 

The other CCP's are regarding laminating. One is about the hardening of the adhesive. Carcinogens can be created by poor hardening conditions. This is controlled by temperature and time. The temperature of the environment is measured and products cannot be further processed until enough time has passed. The other one is about the mixing ratio of the adhesive and the hardener. If this is incorrect it could lead to carcinogenics during hardening in the end product which might in turn migrate to foodstuffs. In this case there are specific values to check if the mixing ratio is sufficient.

 

I would like to hear your opinions on these CCP's and if possible advice.

[weaam]

Dear,

I work in a food contact flexible packaging company and we have the BRCGS. Non of the CCPs you mentioned are considered as CCPs in our company first we consider the drying of the ink as an OPRP and the solvent retention is measured on GC for each job to assure that it is within limits. As for glue dryness, mix ratio and printing errors are all considered as PRPs. The only CCP we have is for microbiological testing of the waxed paper at the end of waxing step. 

Be aware of having CCPs without clear limits and a frequency of measurements otherwise you will get a NC. Last year we got a NC because we didn't mention how frequently we do the testing, 

We also used to have printing errors as a CCP but the auditor wasn't convinced that it should be a CCP so we changed it into PRP. 

This year the auditor was satisfied with the only CCP we have and the others mentioned as OPRP and PRPs.

Hope that this will help.