HACCP for Packaging

The Hazard Analysis Critical Control Point (HACCP) concept has been used in the food industry to control hazards associated with food processing. Previously, the application of HACCP was limited to food manufacturing. However, recently HACCP applications to the process of food packaging have begun to take hold. The packaging supplier is now seen as a crucial step in the overall process of ensuring food safety, which begins with manufacturing and ends with consumption. As a result, direct food contact packaging is now treated as a food ingredient in most cases. Thus, the principles of HACCP may be applied to existing programs in the packaging industry to create a series of steps ensuring that food safety is maintained throughout the packaging process. Such steps involve setting up clear Critical Control Points in which hazards may be controlled for and eliminated. These steps will allow packaging suppliers to better control for hazards that may contaminate the food product during packaging, and thus better ensure customer safety.

Definitions

HACCP- Hazard Analysis Critical Control Point- A systematic approach to food safety hazard identification.
CCP- Critical Control Point- The last point in the process which a food safety hazard can be prevented, eliminated, or reduced to an acceptable level.
Hazard- A chemical, physical or biological agent that is reasonably likely to cause injury or illness.
PP- Prerequisite Programs- Operational support systems that allow the plant to produce safe products.

About HACCP

HACCP was originally developed for NASA to prevent food borne illnesses for astronauts.
It was initially developed through a joint effort by NASA and Pillsbury in order to ensure safe food for space exploration.
HACCP is now mandated by the FSIS (USDA) for meat and poultry products and by the FDA for seafood and juices.

Application to Food Packaging

In recent years, suppliers of food product packaging have become increasingly considered a part of the food manufacturing industry. While HACCP was not originally designed for packaging, more and more resources are available to assist packaging companies in implementing a HACCP-based program. Several food safety certifications now designed for packaging have strong emphasis on HACCP.

An HACCP-based system operates on prerequisite programs which help management ensure that products are produced in a safe manner. Prerequisite programs are often times programs that are already in place at a packaging supplier as a part of the current quality management system. Prerequisite programs can include:

Good Manufacturing Practices
Integrated Pest Management System
Preventative Maintenance Program
Supplier Management Program
Traceability & Recall Program
Documentation and Record Keeping
Allergen Awareness Management Program
Foreign Material and Detection Control>
Cleaning and Sanitation Program
Corrective Action Program

Principles of HACCP

There are seven principles of HACCP that allow packaging companies to review their production with a systematic approach to identifying hazards. These principles are used as steps to define a new HACCP program or make changes to an existing HACCP program.

Conduct a hazard analysis- plants will determine what hazards are present in each step of the process and what preventative measures can be applied to control the hazards.
Identify critical control points- A decision tree is used to identify steps where control can be applied and as a result, a hazard can be prevented, eliminated or reduced to acceptable level. Often times packaging suppliers may have very few CCP’s in their process.
Establish critical limits for each critical control point- A critical limit is the minimum or maximum value to prevent, eliminate or reduce that hazard to an acceptable level.
Establish control point monitoring requirements- monitoring activities are necessary to ensure the critical limits are being met at each critical control point.
Establishing corrective actions-These are actions to be taken when there is a deviation for the established critical limits. Corrective actions are intended to ensure that no product with a hazard enters commerce.
Establish record keeping procedures- HACCP regulations require that plants maintain certain documentation which includes a written HACCP plan, hazard analysis, and records documenting the monitoring of CCPs, critical limits, verification activities and the handling of process deviations.
Establish a procedure for verifying the HACCP system is working- Validation ensures the plant is do what they are designed to do. Verification ensures the HACCP plan is adequate.

Common Critical Control Points Seen within the Packaging Industry

Allergens: When packaging is labeled or decorated (which may include food ingredients statements) it is critical for packaging suppliers to have controls in place to use the most current version of the ingredients statement.

Metal: When there is a risk of metal contamination packaging suppliers may have a CCP for metal detection where products would pass through a case pack metal detector

Food packaging suppliers must be aware of the increasing level of emphasis on packaging as itself an ingredient and a crucial step in the overall process of food manufacturing, specifically in terms of the potential for hazard contamination in the food source during this stage. In light of this, the principles of HACCP must be seen as essential components in the process of food packaging. HACCP allows food packagers to identify what potential hazards there may be, how to control for them, and how to determine the extent to which the hazard has been eliminated or reduced to an acceptable level. While HACCP may be applied to preexisting programs, packaging suppliers must be able to implement and maintain a core CCP structure, which would identify the steps in the packaging process in which hazards would be most likely to occur and where safety measure may be most applicable in order to control for such hazards. While HACCP is taking hold in many food packaging suppliers, many still have not developed sufficient CCPs in their packaging processes. As a result, it is increasingly important to determine if the supplier you are using has a HACCP plan or food safety certification.