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EXAMPLE

PACKAGING SUPPLIER
HACCP PLAN

For Manufacture of
Primary Packaging Material
Printed Film
Manufacturing Location
Date

Note: This Packaging Supplier HACCP plan is written from the


perspective of hazards and risks associated with the package and
food within the finished package—as to be consumed by the
consumer.

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Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type A, B, and C), Printing Process (X, Y, or Z) Supercedes: New

Form A – EXAMPLE

Product/Product Category Description

Product/Product Category Film to be used for liquid food products, non hot-fill
(e.g., salad dressing single serve pouches-- primary
package)

Process Extruded polymer film (A, B, and C polymers), printed


(define type: flexo, litho, or rotogravure)

Food Safety Characteristics Film to provide barrier for food after food is packaged.

Film labels must be accurate for finished food product


to be packaged to prevent potential for allergen
product to be packaged in a package not labeled for
the allergen.

Target Market Finished food product target all consumer markets.

Consumer/Customer Use Finished film to be used as pouch for liquid food


products, consumers to open pouch and use per type
of food (e.g., salad dressing)

Labeling/Label Instructions Film identified by core tag and tag on exterior of roll

Packaging Film web rolls placed on pallets with top and bottom
slipsheets, pallet is stretch-wrapped.

Shelf Life Shelf life specific for type of polymer used (time
dependent on optimum machinability for subsequent
food packaging lines)

Storage & Distribution Stored at internal plant warehouse, distributed to food


manufacturing plants, ambient temperature
Note: Some polymers may require more strict
temp/RH conditions

(Note: To view flow charts on the pages to follow, the “Print Layout View” of MS Word must be
used—pages appear blank on monitor in “Normal View”.)

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Kraft North America Corporation, Kraft Foods Global, Inc.
EXAMPLE-- PROCESS FLOW CHART
PRINTED EXTRUDED FILM—TYPES A, B, and C

MATERIALS RECEIVING/STORAGE

PP Bulk Railcar Receiving for Polymer Resin Pellets


PP Raw Material
Receiving (via trucks) Regulatory Approval
Letters received or on file Resin Pellets unloaded from railcars-- air-
as appropriate per material conveyed to storage silos (silos dedicated
Storage in Warehouse polymer-specific)

FILM MANUFACTURING OPERATION


Forklift transport to production as
needed (inks, pallets, spools,
slipsheets, stretch-wrap, etc.) Polymer pellets air-conveyed to pellet hoppers above extruder

PP Magnet

Resin pellets fed into extruder

PP Pellets melted (~300-600ºF) in extruder

PP Melted polymers pass through mesh screen

Film extruded through extruder die plate

Film rolled between rollers to desired thickness

Water recirculated,
PP Film quenched in water bath (recirculated, treated water)
treated with biocide

Cooled film wound onto roller spool, film rolls labeled

Rolls identified to be reworked are


Spools of film placed onto pallets (w/slipsheets),
separated, labeled, moved to hold covered with slipsheet, pallets labeled
area pending reworking or recycling

Film moved to curing storage area or curing room as required per


film type (Temp/RH controlled), cure time polymer/film specific

To PRINTING OPERATION

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Kraft North America Corporation, Kraft Foods Global, Inc.
GRAPHICS / ARTWORK PREPARATION
0

Print graphic design and artwork created

Resource code and UPC assigned

Sign-off approvals (Customer: Marketing, Regulatory, Pkg. Quality, R & D, Nutrition, ...)

Graphic design submitted to 3rd party graphics company for final development

CCP Final design proof copy sent back to Originator for final official sign-off and approval
for Customer

Graphics company sends film, plates, cylinders, or digital file (dependent on type
of printing) to packaging supplier (with proof copy)

Packaging supplier makes plates per film or file from Graphics company

CCP 1 Packaging supplier verifies plates match original proof copy supplied by customer
(Print Copy Verification)—may only be able to be verified on actual press—dependent
on process

Plates stored until job requested for printing by pressroom

To PRINTING OPERATION

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Kraft North America Corporation, Kraft Foods Global, Inc.
1 PRINTING OPERATION—Printing Presses X, Y, and Z

Previous job on printing press completed

CCP 2 LINE CLEARANCE PROCEDURE FOLLOWED—Utilize Line Clearance Checklist:


- All rolls and partial rolls of film from prior run labeled, pallets stretch-wrapped, and
removed from area to designated warehouse location (note: film left in rollers of printing
press only for threading next job—must be destroyed after new film threaded through
machine
- All pre-printed roll and pallet labels from previous run removed/destroyed
- Line clearance paperwork completed, verified by supervisor (or other designated

New Job Order—


Traveler received
Materials brought to line for specific job (printing plates, ink, film, rolls, labels,
slipsheets, pallets, ..)

Press operator sets up press with plates, ink, etc.. for new job order

New blank film spliced (w/tape) to tail from previous run to thread through machine rollers

CCP 2 Initial film out of press run out until new print order is through all rollers, previous
(part of Line
Clearance CCP) run film tail cut off and destroyed (prior run film is not allowed to be run onto spool
of new run unless print rolls are lifted and film left in press is blank).

CCP 1 Press sample of printed film compared to proof supplied by customer,


checked for: print accuracy, SKU, colors, other quality specifications

Starch (Oxi-dry) sprayed on film (optional per type of film and application)

Core tags printed


specific for job Printed film rolled onto Master roll (to be OR
slit on separate Finishing line/operation)
Pallet labels printed
specific for job SAME LINE
Rolls placed on pallets, labeled w/ core tag ID
PP
and pallet labels

Rolls identified to be
reworked are separated, Pallets with master rolls staged for Finishing operation
labeled, moved to hold
area pending reworking

To FINISHING OPERATION
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Kraft North America Corporation, Kraft Foods Global, Inc.
FINISHING OPERATION

CCP 2 Line Clearance Procedure (for Finishing Operation)

Printed film slit into rows and wound onto individual cores
Core tags printed
specific for job

Completed rolls labeled inside core and outside roll with core tags
PP

Pallet labels printed


specific for job
Rolls placed on pallets on top of slipsheets, completed pallets stretch-wrapped
PP and labeled

Rolls identified to be
reworked are separated,
labeled, moved to hold
area pending reworking

Stretch-wrapped pallets of film moved to designated warehouse storage area

Rolls of film staged and shipped to customers per customer orders

REWORK OPERATION

Rolls to be reworked PP Rolls reworked by specific SKU, good product


moved from hold or staging labeled appropriately
area to rework area
Line Clearance Procedures
CCP 2 followed between jobs

Good rolls moved to normal Non-usable material destroyed as scrap


storage areas per type of or recycled (dependent on type of film
material, available for shipment and print)

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Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Form C - Example

Ingredient/Packaging Assessment / Hazard Analysis

Polymer Film (type a, b, and c) Printed (process x, y, and z)


STORAGE BIOLOGICAL HAZARD BIOLOGICAL HAZARD CHEMICAL HAZARD CHEMICAL HAZARD PHYSICAL HAZARD PHYSICAL HAZARD
RAW MATERIAL
NUMBER MATERIAL NAME
CONDITION
A = Ambient
VP=Vegetative Pathogens
SP=Spore forming
CONTROL MECHANISMS
(___-CCP)
(Allergens, Sulphites,
Mycotoxins, Antibiotics, CONTROL MECHANISMS * Inherent to ingredient and its CONTROL MECHANISMS
packaging (___-CCP)
F = Frozen Pathogens Pesticides, Heavy Metals) (___-CCP) (Metal, Glass, Hard Plastic)
R = Refrigerated (___- PP) (___- PP)
(___- PP)

#4567 Polymer Resin A, B, and A None None Heavy metals PP: Regulatory Approval Metal or extraneous from pellet PP: Magnet at resin pellet
#4568 C Pellets Letter from supplier (e.g., manufacturing process hopper (Rare Earth, x# bars)
#4569 KNAC: FDA, CONEG) —
Approved for direct food PP: Screen (X# mesh) at
contact packaging extruder

#3210 Cooling Water A VP PP: City Water chlorinated, None None None None
(recirculated) recirculated water treated
with biocide

#4321 Biocide X A None None Chemical (non-food grade) PP: MSDS and/or None None
(used in cooling water) Regulatory Approval Letter
from supplier-- Approved for
use for cooling water used
for direct food contact
materials

#9876 Printing Inks X, Y, Z A None None Heavy metals PP: Regulatory Approval None None
#9877 Letter (e.g., KNAC: FDA),
#9878 CONEG) — Approved for
use on specific type of
packaging materials, Heavy
Metals Warranty from
supplier

#5432 Starch (Corn) A None None None None None None

#6543 Roll Core A None None Heavy metals PP: Regulatory approved for None None
incidental food contact

#3345 Stretch-Wrap Film A None None Heavy metals PP: Regulatory approved for None None
incidental food contact

#9987 Slipsheets (cardboard) A None None Heavy metals PP: Regulatory approved for None None
incidental food contact

#8765 Tape A None None None None None None

#7654 Pallets A None None None None Wood splinters, nails, other PP: Inspection process for
extraneous pallets, use of slip sheets,
GMP

Rework A None None None None None None


N/A

672653348.doc updated: 10-Oct-04 7 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Form D - Example Processing Step Evaluation / Hazard Analysis

Film to be used for Primary Packaging


BIOLOGICAL BIOLOGICAL HAZARD CHEMICAL CHEMICAL HAZARD PHYSICAL PHYSICAL HAZARD
PROCESSING STEP HAZARD CONTROL MECHANISMS HAZARD
CONTROL MECHANISMS * HAZARD CONTROL MECHANISMS
VP=Vegetative Pathogens (___-CCP) (Allergens, Sulphites, Inherent to equipment or (___-CCP)
SP=Sporeforming Pathogens Mycotoxins, Antibiotics, (___-CCP) environment.
(___- PP) Pesticides, Heavy Metals) (Metal, Glass, Hard Plastic) (___- PP)
(___- PP)
MATERIAL RECEIVING AND STORAGE

Polymer resin pellet receiving—Railcar bulk unloading, VP- from bulk unloading PP: Heat process for extrusion None None Incidental Extraneous from PP: Magnet at resin pellet
pellets air-conveyed to silo storage (silos are specific for process and/or compressed air (~300-600ºF) bulk railcar unloading process hopper (Rare Earth, x# bars)
type of polymer)
PP: Screen (X# mesh) at
extruder

Other materials receiving (from trucks) and warehouse None None None None None None
storage (empty cores, stretch-wrap film, slipsheets, ink,..)
Polymer resin pellets air-conveyed to hopper above VP- from compressed air PP: Heat process for extrusion None None None None
extruder (~300-600ºF)
Pellets gravity fed over magnet to extruder None None None None None None

Pellets heated and melted inside extruder None None None None None None

Melted polymer passes through #x mesh screen and None None None None None None
extruded through dies to form film
Hot film cooled in water tank (re-circulated water treated None None None None None None
with biocide)
Film rolled through rollers to proper thickness None None None None None None

Film wound onto roll core None None None None None None

Rolls labeled and put onto pallets on a slipsheet None None None None None None

Pallets of rolls covered with slipsheet and moved to curing None None None None None None
area or room
Rolls of film cured for designated time (e.g., 1 week) at None None None None None None
Temp/RH specific for polymer
Rolls of film identified as rework separated, labeled, None None None None None None
moved to hold area

672653348.doc updated: 10-Oct-04 8 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

BIOLOGICAL BIOLOGICAL HAZARD CHEMICAL CHEMICAL HAZARD PHYSICAL PHYSICAL HAZARD


PROCESSING STEP HAZARD CONTROL MECHANISMS HAZARD
CONTROL MECHANISMS * HAZARD CONTROL MECHANISMS
VP=Vegetative Pathogens (___-CCP) (Allergens, Sulphites, Inherent to equipment or (___-CCP)
SP=Sporeforming Pathogens Mycotoxins, Antibiotics, (___-CCP) environment.
(___- PP) Pesticides, Heavy Metals) (Metal, Glass, Hard Plastic) (___- PP)
(___- PP)
PRE-PRINTING OPERATION

Original graphics final proof copy reviewed, approved, and None None Allergen—potential for CCP for customer: None None
signed off by customer (Kraft) prior to submitting to mislabeling if printing is Verify final proof copy is
supplier for use in production incorrect correct

For each production run, printing plates are created from None None Allergen—potential for CCP 1: Verify print copy None None
film or digital file received from customer (for Kraft-- mislabeling if printing is for new plates/cylinders
through 3rd Party Graphics Company). Plates checked for incorrect matches original proof copy
accuracy and print quality compared to original proof copy received from customer
received from customer prior to release for production. (dependent on process,
(For rotogravure process, cylinders may be made by 3rd accurate check may only be
party graphics company) available at first press
sample).

PRINTING OPERATION

Line clearance procedure (utilizing checklist) completed None None Allergen—potential for mixing CCP 2: Line Changeover / None None
and documented for previous printing job—all material labels from previous and new Clearance Procedures
from previous run removed from area (including: all rolls run (if allergen/non-allergen) (Checklist)
of printed film and partial rolls; printing press plates or
cylinders (unless utilized for next print job); all pre-printed
core and pallet labels (pre-printed labels must be
destroyed)
NOTE: Film threaded through printing press rollers is
usually left in printing press to assist in threading the new
film through for the next run—film tail used to thread press
must be destroyed and not run onto new roll OR print rolls
are lifted at end of run to assure that tail left in press is
blank film

Press operator receives work order (Traveler) for specific None None None None None None
job and installs correct printing plates on presses per
specific order
Materials needed for printing job (specific blank film, ink, None None None None None None
slipsheets, stretch-wrap film, ..) are moved to printing
operation
Film web spliced (w/tape) to film web in machine None None Allergen—potential for mixing CCP 2: Line Changeover / None None
(previous run) and fed onto printing press through series labels on the same roll (if Clearance Procedures
of cylinders allergen/non-allergen) (Checklist)

Initial film out of printing press rollers cut off (previous run None None Allergen—potential for mixing CCP 2: Line Changeover / None None
material that was spliced to new film) – previous run labels on the same roll (if Clearance Procedures
material not allowed to be run onto spool for new run allergen/non-allergen) (Checklist)
unless print rollers are lifted and film left in press from
previous run is blank
Press sample of printed film at printing press compared to None None Allergen—potential for CCP 1: Verify print copy-- None None
proof supplied by customer, checked for: print accuracy, mislabeling if printing is first press sample matches
SKU, colors, other quality specifications incorrect proof copy received from
customer

Starch (corn) sprayed onto film at slitter (optional per type None None None None None None
of film and application)

672653348.doc updated: 10-Oct-04 9 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

BIOLOGICAL BIOLOGICAL HAZARD CHEMICAL CHEMICAL HAZARD PHYSICAL PHYSICAL HAZARD


PROCESSING STEP HAZARD CONTROL MECHANISMS HAZARD
CONTROL MECHANISMS * HAZARD CONTROL MECHANISMS
VP=Vegetative Pathogens (___-CCP) (Allergens, Sulphites, Inherent to equipment or (___-CCP)
SP=Sporeforming Pathogens Mycotoxins, Antibiotics, (___-CCP) environment.
(___- PP) Pesticides, Heavy Metals) (Metal, Glass, Hard Plastic) (___- PP)
(___- PP)
Printed film rolled onto Master Roll (OR goes directly to None None None None None None
Finishing Operation on same line)
Film rolls identified to be reworked are labeled, separated None None Allergen—potential for PP: Employee Training and None None
from good production, moved to hold area pending rework mislabeling rolls and/or pallets correct standard operating
process (if allergen/non-allergen) procedures (SOP) followed

Master rolls labeled with core tags and pallet labels None None Allergen—potential for PP: Employee Training and None None
specific for job mislabeling rolls and/or pallets correct standard operating
(if allergen/non-allergen) procedures (SOP) followed

Master rolls staged for finishing process None None None None None None

FINISHING OPERATION

Line clearance procedure (utilizing checklist) completed None None Allergen—potential for mixing CCP 2: Line Changeover / None None
and documented for previous printing job—all material labels from previous and new Clearance Procedures
from previous run removed from area (including: all rolls run (if allergen/non-allergen) (Checklist)
of printed film and partial rolls; all pre-printed core and
pallet labels (pre-printed labels must be destroyed)
Master rolls brought to slitting/finishing equipment (OR None None None None None None
film from printing press continues on same equipment)
Film slit into rows and wound onto individual cores None None None None None None

Film rolls labeled with core tags on inside of core and None None Allergen—potential for PP: Employee Training and None None
outside roll. mislabeling rolls (if correct standard operating
allergen/non-allergen) procedures (SOP) followed

Film rolls put onto pallets with slipsheet, stretch-wrapped, None None Allergen—potential for PP: Employee Training and None None
pallets labeled mislabeling pallets (if correct standard operating
allergen/non-allergen) procedures (SOP) followed

Film rolls identified to be reworked are labeled, separated None None Allergen—potential for PP: Employee Training and None None
from good production, moved to hold area pending rework mislabeling rolls and/or pallets correct standard operating
process (if allergen/non-allergen) procedures (SOP) followed

Pallets of film rolls moved to warehouse storage area None None None None None None

Film rolls shipped per customer orders. None None None None None None

672653348.doc updated: 10-Oct-04 10 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

BIOLOGICAL BIOLOGICAL HAZARD CHEMICAL CHEMICAL HAZARD PHYSICAL PHYSICAL HAZARD


PROCESSING STEP HAZARD CONTROL MECHANISMS HAZARD
CONTROL MECHANISMS * HAZARD CONTROL MECHANISMS
VP=Vegetative Pathogens (___-CCP) (Allergens, Sulphites, Inherent to equipment or (___-CCP)
SP=Sporeforming Pathogens Mycotoxins, Antibiotics, (___-CCP) environment.
(___- PP) Pesticides, Heavy Metals) (Metal, Glass, Hard Plastic) (___- PP)
(___- PP)
REWORK Process None None Allergen—potential for mixed CCP 2: Line Changeover / None None
labels (allergen/non-allergen) if Clearance Procedures
Line Changeover/Clearance (Checklist)
Procedures not followed (e.g.,
mixed labels if rolls incorrectly
spiced during rework process)

Allergen-- potential for PP: Employee Training and


mislabeling rolls and pallets correct standard operating
with incorrect label (if procedures (SOP) followed
allergen/non-allergen)

672653348.doc updated: 10-Oct-04 11 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

FORM E-1 – Example

INGREDIENT ALLERGEN ASSESSMENT

Note: Full Allergen Assessment consists of Forms E-1, E-2 and E-3

Ingredients/Components for Manufacturing Lines X, Y, and Z

List all ingredients containing List identified allergens/sulfites List identified carry over
allergens/sulfites* and containing of ingredients allergens/sulfites
carryover allergens/sulfites per allergen
profile of raw material spec.

None None None

*Allergens identified by Kraft Foods Allergen List, reference the Kraft Foods Supplier Quality Expectations or the Kraft
Foods Supplier HACCP Guide/Standard.

672653348.doc updated: 10-Oct-04 12 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

FORM E –2 – Example

ALLERGEN CROSS- CONTACT PRODUCTION ASSESSMENT

Note: Full Allergen Assessment consists of Forms E-1, E-2, and E-3

Products: A, B, and C (All films are capable of running on Lines X, Y, and Z)


Manufacturing Lines: X, Y, and Z

List all products produced on the Are all identified allergens (per If “No” identify control mechanism(s)
manufacturing line including use of ingredient allergen assessment E-1, (_ - CCP)
common equipment e.g. rework tanks, column B and C) labeled? (_ - PP)
fillers etc.
YES (list allergens) NO

Product A (Lines X, Y, and Z) None

Product B (Lines X, Y, and Z) None

Product C (Lines X, Y, and Z) None

672653348.doc updated: 10-Oct-04 13 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Form E-3 – Example

PRINT COPY ALLERGEN LABELING ASSESSMENT

Note: Full Allergen Assessment consists of Forms E-1, E-2, and E-3

Allergens Declared in Ingredient List On Printed Film Per Manufacturing Line

A B C
Manufacturing Line List all SKU’s with allergen/sulfites listed as components in List identified allergens/sulfites* per
print copy containing allergens/sulfites* SKU

Lines: X, Y, and Z Extreme Flavor A Salad Dressing 16 oz 0 99999 99999 0 Milk, Eggs, Peanuts, Soybean
Extreme Flavor A Salad Dressing 12 oz 0 99999 99991 0
Extreme Flavor A Salad Dressing 8 oz 0 99999 00002 0
Extreme Flavor B Salad Dressing 16 oz 0 99999 00003 0
Extreme Flavor B Salad Dressing 12 oz 0 99999 00004 0
Extreme Flavor B Salad Dressing 8 oz 0 99999 00005 0

Lines: X and Z Minimum Flavor Salad Dressing 12 oz 0 88888 88888 0 Milk, Eggs, Wheat Flour
Minimum Flavor Salad Dressing 8 oz 0 88888 88881 0

Lines: Y and Z Medium Flavor Salad Dressing 12 oz 0 77777 77777 0 Milk, Eggs, Peanuts, Almonds

Lines: X, Y, Z Generic Flavor Salad Dressing 10 oz 0 22222 22222 0 Wheat Protein, Poppyseeds, Almonds
Generic Flavor Salad Dressing 14 oz 0 22222 22221 0

672653348.doc updated: 10-Oct-04 14 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

FORM F - EXAMPLE

PRODUCT/PROCESS HAZARD EVALUATION SUMMARY


PURPOSE: Provides a summary of identified hazards, control mechanisms, identification of the CCP (s), and an overview of hazard management. Also, form F identifies
Prerequisite Programs that must be documented and implemented.
NOTE: If control mechanisms have been determined for all identified hazards and documented in Forms C, D, and E – 1 & E - 2, then Form F is optional.

HAZARD IDENTIFIED CONTROL If the hazard is managed as If the hazard is managed as a


MECHANISM (S) a CCP, list CCP Prerequisite Program, list the
Prerequisite Program name.
BIOLOGICAL
Vegetative Pathogens (VP) City water chlorinated, PP: Water treatment. Employee Training
in recirculated cooling water recirculated water and correct standard operating procedures
treated with biocide, (SOP) followed.
tank drained and
cleaned 1x per week,
water micro tested
weekly
VP from bulk railcar Pellets heated to 300º- Not managed as a CCP because if the
unloading process for resin 600ºF prior to extrusion temperature is not reached the product
polymer pellets process could not be made into film. (Temperature
exceeds food safety limit for VP)
VP from air conveying Pellets heated to 300º- Not managed as a CCP because if the
system for resin polymer 600ºF prior to extrusion temperature is not reached the product
pellets process could not be made into film. (Temperature
exceeds food safety limit for VP)

672653348.doc updated: 10-Oct-04 15 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

HAZARD IDENTIFIED CONTROL If the hazard is managed as If the hazard is managed as a


MECHANISM (S) a CCP, list CCP Prerequisite Program, list the
Prerequisite Program name.
CHEMICAL
Heavy metals Regulatory Approval PP: Regulatory Approval Letters received
(from: inks, roll core, stretch- Letters from suppliers with shipment or on file certifying material
wrap film, slipsheets) (e.g., KNAC: FDA, meets regulations for specific use
CONEG)—approved
for specific use

Non-Food Grade Chemical MSDS and/or PP: MSDS and/or Regulatory Approval
(Biocide used for Regulatory Approval Letter from supplier certifying chemical is
recirculated cooling water) Letter from supplier approved for use in cooling water for
primary packaging material

Allergen (print copy error-- Originator (customer) CCP (for customer): Print
potential for unlabeled and 3rd party graphics proof copy verification and
allergen after food is responsible for original approval-- Print/graphics
packaged) print copy to be correct. must be proofread and
approved as correct
ingredient line, etc.. prior to
submitting to printing supplier

672653348.doc updated: 10-Oct-04 16 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

HAZARD IDENTIFIED CONTROL If the hazard is managed as If the hazard is managed as a


MECHANISM (S) a CCP, list CCP Prerequisite Program, list the
Prerequisite Program name.
Allergen (print error due to Plates and/or cylinders CCP 1: Print Copy
plate error-- potential for checked against Verification for plates and/or
unlabeled allergen after food original print copy after cylinders-- Press operator
is packaged) being made, prior to checks initial press sample
release for use on as matching proof copy.
printing press OR at
initial first press sample
(process dependent)

Allergen—mixed labels on a Line Changeover / CCP 2: Line Changeover /


roll due to splicing new job to Clearance Procedures Clearance Procedures
previous job and running —Utilize Checklist (Checklist)
onto the same roll—
(potential for unlabeled
allergen after food is
packaged)

Allergen—mislabeling roll or Line Changeover / CCP 2: Line Changeover / PP: Employee Training and correct
pallet with an incorrect label Clearance Procedures Clearance Procedures standard operating procedures (SOP)
(potential for unlabeled —Utilize Checklist (Checklist) followed
allergen after food is (remove/destroy all
packaged) pre-printed labels from
previous run)

672653348.doc updated: 10-Oct-04 17 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

HAZARD IDENTIFIED CONTROL If the hazard is managed as If the hazard is managed as a


MECHANISM (S) a CCP, list CCP Prerequisite Program, list the
Prerequisite Program name.
PHYSICAL
Metal or extraneous in resin Magnet at resin hopper PP: Magnet
pellet raw material (from at extruder
pellet manufacturing PP: Screen
process) Screen at extruder

Wood splinters, nails, other Inspection process for PP: Incoming inspection procedures
extraneous from wooden pallets,
pallets Slip sheets used above
and below film rolls on PP: SOP for use of slip sheets before
pallet putting rolls on pallets
Incidental Extraneous Magnet at bulk
(Metal, wood, glass, rocks, unloading process PP: Magnet
etc.) in polymer pellets from
bulk railcar unloading Screen at extruder for PP: Screen
process melted polymer

672653348.doc updated: 10-Oct-04 18 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Form G - EXAMPLE
CCP Documentation
Note: The CCP documentation would need to be edited to be specific for the material and operation at
the packaging supplier.

CCP 1
PRINT COPY VERIFICATION
Critical Control Point ID:
Verification that print copy from actual press plates or cylinders match the print
copy of the proof submitted by the customer.

Hazard:
Hazard is the potential to have a mislabeled or unlabeled allergen on a food
package after food is packaged by the food manufacturer (customer).

Critical Limit:
Print copy from actual printing press plates and/or cylinders must be exact match
to print copy proof provided by customer (hazard specifically for film that has
allergen ingredients listed, allergen ingredients and wording must be correctly
printed).

Monitoring Activity/ Frequency:


Print copy accuracy is verified with each new plate or cylinder made by the plate
maker or set-up technician prior to use on printing press operation (for some
operations this is only possible with the first press sample from the printing
press).

Corrective Action:
If production was started with plates that were found to have incorrect allergen
information, printing press must be stopped, all film produced with the incorrect
print shall be segregated and placed on Category I Hold. Production may
resume after replacing the incorrect plates or cylinders with new plates or
cylinders that have been verified as having the correct print and following the
appropriate Line Changeover / Clearance Procedures.

If film produced with the incorrect print has multiple rows of print and some rows
are correct printing, film may be reworked per appropriate documented rework
process. Good film (with correct printing) may be released to normal distribution.
All printed material with incorrect allergen printing must be destroyed. Film may
not be used for recycle unless written permission from Kraft Foods is obtained.

672653348.doc updated: 10-Oct-04 19 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Responsibility:
Designated trained* employee(s).
*All operators have received training in allergen awareness and understand the
critical nature and potential food safety risk of inadvertent mixing of labeled
packaging materials.

Record/Location
Records can include:
Logs/checklists of print verification (including original proof copy from
customer)
Employee training records
Production run material reconciliation records
Corrective actions taken for CCP violation situations
Verification Records
(Designate a location for each record)

Minimum CCP Verification Activities:


Designated responsible employee (usually a supervisor) reviews, signs and
dates the documents prior to release of plates or cylinders to pressroom to
confirm that correct procedures were followed and documentation is correct and
complete.

HACCP Plan Verification Activity:


A designated employee (usually quality function) reviews the documentation
weekly or at a frequency sufficient to demonstrate control to confirm monitoring
and records are completed correctly. Checked documents are signed and dated.

Scientific Basis:
Monitoring procedure(s) are tested to confirm that they achieve the desired
control. This is documented and stored with the HACCP Plan.
Allergen risk reference 7.2.1, and 7.2.3.1 of the KF WWFC HACCP Standard-
2002.

672653348.doc updated: 10-Oct-04 20 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Form G - EXAMPLE
CCP Documentation
Note: The CCP documentation would need to be edited to be specific for the material and operation at the
packaging supplier.
CCP 2
PRINTING PRESS LINE CHANGEOVER / LINE CLEARANCE PROCESS

Critical Control Point ID:


Changeover of printing press to a new print job-- different printed material

Hazard:
Hazard is the potential to have a mislabeled or unlabeled allergen on a food
package after food is packaged by the food manufacturer (customer).

Note: Potential for this to happen with rolls of printed film include (but not limited to):

- Mixed types of printed film within a roll due to splicing new job onto old job
and allowing new job and old job to go onto same spool
OR
- Mislabeling a roll or pallet with the incorrect label or core tag due to using
incorrect labels from the previous run
OR
- Mixing rolls of unlike film on a single pallet with an incorrect pallet label

Critical Limit:
Printed film is not mixed within a roll, or pallet as produced. Rolls and pallets are
correctly labeled.

Monitoring Activity/ Frequency:


Strict controls and line clearance procedures prior to starting a new printing job
are in place and followed to prevent inadvertent mixing or mislabeling of printed
film. Documented line clearance procedures are in place and followed at each
printing press line changeover.

Procedures include:
- The tail of the previous job left in the printing press rollers (tail is spliced to the
new job blank film for ease of threading the machine) is not allowed to be run
onto a spool at the end of the printing press—tail material is cut off and
destroyed when new print material is threaded through the machine.
AND
- All pre-printed core tags and pallet labels are destroyed or physically removed
from the area after the production run.
AND
- All rolls of printed film from the previous job are placed on pallets and
physically removed from the immediate production area prior to the next run.

672653348.doc updated: 10-Oct-04 21 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Corrective Action:
If production was started and printed film from the previous run was run through
equipment onto a roll core followed by spliced new printed film, the implicated
roll(s) must be placed on Hold and separated from good production. Rolls of
mixed film may be reworked through a rewinding process.

If rolls from new job were mixed on a pallet with rolls from a different production
run, the suspect pallet(s) must be placed on hold. The pallets may be reworked
if the rolls are separated and the pallets correctly labeled.

If rolls or pallets are identified as being mislabeled with the wrong label, suspect
rolls and pallets must be placed on hold. Rolls and pallets may be reworked and
properly identified with the correct labels.

All corrective action activities must be documented and verified by a supervisor


or other designated employee. Reworked film (good) may be released following
verification.

Responsibility:
Designated trained* employee(s).
*All operators have received training in allergen awareness and understand the
critical nature and potential food safety risk of inadvertent mixing of labeled
packaging materials.

Record/Location
Records can include:
Logs/checklists of changeover/line clearance and start-up activities
Employee training records
Production run material reconciliation records
Corrective actions taken for CCP violation situations
Verification Records
(Designate a location for each record)

Minimum CCP Verification Activities:


Designated responsible employee (usually a supervisor) reviews, signs and
dates the documents daily to confirm that correct procedures were followed and
documentation is correct and complete.

HACCP Plan Verification Activity:


A designated employee (usually quality function) reviews the documentation
weekly or at a frequency sufficient to demonstrate control to confirm monitoring
and records are completed correctly. Checked documents are signed and dated.

672653348.doc updated: 10-Oct-04 22 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.
Example Packaging Supplier HACCP Plan Date Issued: 10-Oct-04
Extruded Film (type a, b, and c), Printing Process (X, Y, or Z) Supercedes: New

Scientific Basis:
Monitoring procedure(s) are tested to confirm that they achieve the desired
control. This is documented and stored with the HACCP Plan.
Allergen risk reference 7.2.1, and 7.2.3.1 of the KF WWFC HACCP Standard-
2002..

CCP for Print Copy Verification by the Customer is managed by the Customer

Need to add additional HACCP plan documentation (approvals, validation


process, formula cross-reference index, etc. (Refer to HACCP Standard/Guide.)

672653348.doc updated: 10-Oct-04 23 of 23


Kraft North America Corporation, Kraft Foods Global, Inc.

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