One of our lovely readers has asked us to ask you, what your thoughts are on the following question.  We’d like to get a discussion going about how everyone handles cleaning of glass bottles (or other glass containers) before filling.  The reason for asking is that the technical team at the site is question, is struggling to get the site team on board with validation of the CCP for glass bottle cleaning, and so – they get a lot of push back when doing the validation. This raises the argument about whether this step is actually a CCP or not.  So, we would love to know your view and how you tackle it.

Please help and get involved in the discussion, by putting your thoughts in the reply box below.  Remember, you can keep your reply anonymous – you need to enter your email address, but this won’t be visible on the page (it’s just for us a Techni-K and we’ll keep it to ourselves, we promise!).  The name that you enter will be visible on the page, so be aware of this – either use a nickname, make up something cool or just leave off your surname.

We have thousands of lovely readers on our list, so the combined knowledge and experience we have is phenomenal – let’s use it to help each other out.

The question…

If glass containers are being used in a manufacturing process and air blown or product rinsed to clean them, do you class this process step as a CCP?

And if you do, what process do you use for validation of this CCP?

The reply…

When answering, please try to explain why you think it should/shouldn’t be a CCP.  And, if you think it should be a CCP, please explain your thinking behind why you have implemented the validation process that you have.

Have your say…

23 thoughts on “Glass bottling discussion

  1. I used to use glass bottles in a previous place of work, and it was never considered a CCP.

    Assuming the appropriate controls and risk assessments are in place, it fell under pre-requisites.

    You do have to have an utterly brilliant glass breakage procedure though……..

      1. That’s a good point.

        The glass jars came as sealed units in pre-packed cases. Only opened and filled by hand as a part of a very artisan procedure. Part of this was a visual inspection by the operators who were trained specifically for this job.

        So not exactly as the question above, but thought it useful.

        My view is that some of the answer to this depends on how the bottles are purchased and handled. Are they certified sterile / clean / pre-sealed? Loaded to the machine manually or automatically?

  2. Hi,

    Cleaning of glass bottles immediately prior to filling is a CCP as it eliminates the possibility of glass fragments and other contaminates such as carton dust, insects or paint flakes getting into the product.

    Holmach has a variety of solutions for doing this, based on the product to be filled and the nature of the glass container. They can also be used on other container types.

    Care should be taken to either filter rinse water, or automatically vacuum contaminants away in the case of air cleaning. The choice of whether the cleaning media is hot or cold, ionised or inert gas can also be a factor in design.

  3. Asking whether it is a CCP (codex step 7) without providing any information about the previous steps doesn’t aid an informed decision.
    The answer to whether it is a s CCP depends on what the hazards are and how frequently are they present?
    It is usual for glass containers to be stored upside down and shrink-wrapped, so provided they are from a reputable supplier, are kept in a clean, dry, pest-free environment, and part-used pallets are re-covered, the chances of contamination are very small.
    In which case I probably wouldn’t class the air blowing/rinsing as a CCP – it is an operational pre-requisite and good practice.

  4. I used to be Technical Manager for a drinks manufacturer and we filled into glass bottles and didn’t have rinsing or air blowing as a CCP. Whether it should be considered a CCP is dependent on the processing method used.

    Bottle rinsing at my company was to remove any potential foreign bodies and not to remove microbial material. The water used for bottle rinsing was filtered town mains, and the drink was filtered into the filler, and the filling tubes were fitted with fine gauze. Once filled and capped the bottles were tunnel pasteurised to ensure microbial stability.

    So to summarise; if the drink is being pasteurised in bottle then the rinsing doesn’t need to be a CCP. If the drink is sterile filled then rinsing is critical.

    1. Hi Chivers,
      Can I ask – how did you manage the hazard of glass? For example, making sure there was no glass in the bottle before it was filled?

  5. I work in drinks manufacturing and use glass bottles. We use either rinsing or air blowing to clean the bottles, and this is a CCP in our process, as it is the last step where control is applied to remove a foreign body, before the bottles are filled. We validate the cleaning of the bottles annually by putting different foreign bodies (hair, glass, cardboard, paper, dust) into test bottles and passing them through the rinser/air blower at the standard operating parameters. If the bottles come out clean and the foreign body is removed, it is considered to have passed the validation test.

  6. Hi
    We pack yogurt into glass jars for a couple of well known supermarkets. We have inversion, air blow out and UV on the line before they are filled.. We check a few jars before and after UV with a TVC and Ent swab on an ad hoc basis but as it is not physically possible to swab every jar it cannot be a CCP, We have it as a control point and cannot run the line if the UV light is not working which the supermarkets and BRC agree with.
    For the air blow out we use a small laminated piece of paper that we put in the jar and check hourly to ensure the air is sufficient on line to blow our any small fragments of glass. We currently count this as a CCP as it can be checked. Again BRC and the supermarkets agree with this on our line. Please remember that every technologist is different and may interpret their own standards differently to each other!
    BRC will be happy as long as it is properly risk assessed and you can demonstrate validation and verification which ever way you go.

  7. For our sites that bottle beer the rinser would be a CCP assuming no post rinser bottle inspector. The CCP is the pressure of the rinser water. Validation is done by putting foreign bodies in to a bottle and checking at set pressure that the FB is removed. FB would be materials that could be possible contaminants eg paper, cardboard, wood, metal, plastic – glass tends not to used these days because it is not something you want to introduce. Some sites use rice or hops for validation. There is also an automatic cut off so if the pressure drops below the pressure limit the line will stop and this is a CCP. Another point to monitor is nozzle alignment and that they are not blocked. This is a visual check that the water jet is reaching the bottom of the inverted bottles.

  8. Hello
    We use over a million glass units per week, and the air rinse is classed as a PRP in our HACCP. The fundamental point regarding whether or not it is a CCP relate to the hazards that have been identified and ‘cannot be controlled by a later step’. So, if we look at the typical issues using glass from a manufacturer…
    1) Micro – if a perceived hazard exists here, where does it originate? The glass process is extremely hot, (nothing will survive) and as a food contact material should be conducted by a reputable supplier in a controlled environment (Supplier control PRP). It should then be shipped to you in a suitable vehicle with protective tertiary packaging, preventing any contamination from pest etc (transport PRP). You should also have controls in place regarding the safe removal (incl timings) of the tertiary packaging. If using a big glass supplier, ask them for full details — they should easily have this info up their sleeves!
    2) Physical – ok, so you’ve identified a risk of broken glass here… how significant is the actual risk and what is the likelihood of the piece being large enough to cause harm? (FDA guidance on hard and sharp objects). Again supplier and transport controls come into play, (if it’s a reputable supplier they’ll have glass breakage controls in place) as do intake checks (rejecting of full pallet when finding broken glass) etc. You’ll also have a thorough glass breakage stop and check policy on site (another PRP), so which of these is going wrong to give the perceived hazard? OR is what you’re actually trying to control potential dust and tiny fragments? (Again FDA guidelines on size – is it a significant hazard and why? – if the pieces are large enough to come into FDA sizes, then would the wash / air rinse actually remove them every time, or are you using an X Ray later in the process?) you’ve also got PRPs relating to line design, warehouse controls and engineering coming into play.
    3) chemical – again heavy metal etc controlled by supplier – ensure that supplier gives you c of c / c of a and food contact certificate (supplier PRP)
    4) allergen – little to no risk

    Having said all this… the hazards and controls are completely different if the wash process is to reuse / recycle existing containers… which is why every HACCP is different!

    In terms of validation, some tips we found…
    1) permanent marker or food safe paint make it easier to identify specific containers on line
    2) use the experience of your glass supplier when conducting checks – glass breaks in quite specific ways, and a experienced lab can determine forces and potential contact points
    3) is the check point actually the filter or tray used to catch debris? Validate by checking across times and conditions
    4) air rinse can be checked with paper and pressure gauges, wet rinse by temperature and pH

    And lastly… invest time and training with your people! We have glass breakage zones (red for pieces found, amber for safety zone) which has made a huge difference in staff understanding, and are lucky enough to have the space off-line to train practically by mocking up a line and hiding fake broken glass (pebbles!!) around it. it really gets the team thinking as to the shears and forces at play and how they can dynamically risk assess each breakage (someone dropping a single glass is a completely different risk level to a capping head going awol with a rotation force and speed).

    Hope this helps!

  9. Our site fills into glass jars, we don’t rinse at all. They are brought from manufacturers who produce glass for the food industry. When they are used they are visually checked and tipped upside down before they are put on the line in case there are any debris in the bottles, We are a small company and most of the process is by hand so this is possible for us. We hot fill and lab results show that no micro elements survive the hot fill process. The best way to decide if it is a CCP is to run it though the decision tree and go with the results.

  10. I work in (mainly) in the wine industry. I’m a consultant and see lots of bottling lines. New bottles usually arrive shrink wrapped on pallets. Not every site has space to store bottles inside and so they can be outside for a period of time.
    As bottle rinsing/blowing is the last step at which any foreign materials can be removed (that are already in the bottle – either originating from the manufacturing process or storage (it happens!), I would always consider rinsing / blowing to be a CCP. Validating can be done by testing with foreign objects at different pressures of water/air to establish a critical limit. An auto stop can be used to ensure the line stops if the pressure falls below this critical limit. This is then verified daily before start up by lowering the pressure and ensuring the machine stops. It’s also important to look at every rinser/air jet to ensure it is functioning correctly – and that includes direction of the water. Air is trickier. Visual checks should be done throughout the bottling to ensure correct functioning.
    As empty bottles can develop condensation during storage, it is also important that validation is done using bottles with moisture inside as it’s harder to remove foreign bodies.
    Every line is different, but this is a really important step – as is the handling of any glass breakages post rinsing but that’s a whole other discussion!

  11. The first step is to conduct and know the difference:Between hazard analysis and Risk assessment? Quantitative & Qualititive Risk Assessment with the HACCP Plans & the Decisions Tree. This is the best methodologies to derive at the decision if it is a CCP or CP. Review all records relating to process and systems of the glass bottles and glass bottling process. Include that into your Supplier programs nand SCARs. Once these have been done the data will lead you to answers that has been scientifically proven. The Sanitation program is also critical and last but not the lease is to include preventative controls into your plan. Hopefully this help steer you in the right directions. Taking a Better process Control class maybe needed.

  12. Hi:
    I work in a sauce industry and we deal with lots of glass jars but it’s not a CCP for our facility. Yes, you need to be super vigilant while handling glass. Some of the things you might want to consider are,
    – Visual inspection of glass jars on receiving to ensure the shipment was not damaged during transportation
    – Line operators should be extra vigilant while handling glass jars during the filling process
    – Random inspection of glass jars to ensure bottles are not chipped, nicked or cracked.
    – We also invert glass jars through bottle inverter before filling to remove any foreign material present inside.
    – And last but not least is the strict implementation of “Glass Breakage Policy”.
    I hope this helps 🙂

  13. Rinsing of empty inverted bottles using high pressure Chlorinated Water or Filtered Air can be classed as a CCP or an OPRP depending on the pre and post systems and PRPs.
    A 3D Presco camera and reject system can also be used.
    Periodic monitoring of the critical limit ie water or air pressure will also have to be checked and recorded. The visible &/or audible fail safes require challenge testing or verifying at start and end of production run or after a break and downtime. Validation of the process can be conducted independently by pre loading empty bottles with common contaminants found in the factory environment and also received via complaints and passing through the rinser / blower and inspecting to see the effectiveness of the rinser units.

  14. Our bottles are inverted and then air blown prior to filling and as some previous replies have said we consider this a CCP as we have had issues with our supplier in the past so have assessed there is an element of risk that contamination could be present and also this is the last opportunity to remove any physical contamination before filling and there are no additional controls downstream. The issue we have had is in relation to validation as we are not keen in testing with glass, are there any alternatives that could be used as a test piece and would effectively represent a piece of glass?

  15. We use glass bottles and they are reused and washed. Ours isn’t CCP and we also have the scanner in place for FB control passed this. You are still however looking from different angles (FB and micro – efficiency of a wash and rinse). It very much depends what your process look like as well as controls and checks in place.

  16. By definition, CCP is the point/step beyond which if there is no control an identified hazard could increase to unacceptable levels. These hazards could be chemical, physical or microbiological. At this point critical limits are set and operationally controlled.
    Now cleaning if used as a CCP must identify the particular hazard of interest.
    The limits set must be measurable and evidence documented for due diligence,
    From the above, cleaning should not necessarily be a CCP but a CP. Where the activity could be verified on routine basis and documented.
    If the team is considering cleaning as a step to control breakage and glass contamination where there is no step down stream to reject damaged packs then an adequate measuring tool plus visual checks should be in place. With this validation is possible although practically it is not safe to intentionally bring broken bottles or cracked bottles in the production floor in the first place.
    X rays/Scanners have been mentioned although I have not handled them before.

  17. Issues to consider when deciding glass washing is a CCP:-

    * What food is going to be contained in the glass container?
    * How will the glass container be sealed?
    * What prior control steps could act as the CCP for the food product (if indeed one is required)?
    * What chance is there that the glass itself could get damaged and present a physical contamination risk to the food? That point alone might qualify this step as a CCP regardless of any other considerations.
    These questions are just off the top of my head – there may very well be others.

  18. Hi

    It doesn’t matter if its a CCP, PRP, OPRP. Its your HACCP and your risk assessment and if applied correctly you will get to the correct answer depending on your individual process.

    However if the rinsing is there to remove potential foreign body hazards prior to filling, you should validate the operation under worst case scenario conditions and verify controls are working during filling operations, regardless of its designation.

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