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CCP - Acceptable to bypass with management's consent?

CCP Critical Control Point Management

Best Answer Mr. Incognito, 30 April 2014 - 03:11 PM

I agree with Caz.

 

Michael this is some really serious stuff... people go to jail for massive illness or injury incidents especially when it is something they do blatantly and they knew that it could cause illness or injury.  If you have a piece of equipment break down enough to spread metal fragments throughout your product stream that isn't picked up at a CP or found by quality and if it ends up in the body of consumers you may find yourself without a job (company closes due to major recall/injuries) or in jail.

 

In the very least I would:

if you have a food safety team convene a meeting of it and make sure that the meeting minutes show that you brought up that injury to consumers downstream of your process is likely, which is the definition of what a CCP stops, and that you are completely against this. 

 

Better yet:

Find a new job... before they do this.  If they are disregarding food safety this strongly they will do it again.  And even worse if you roll over on this issue now they will know you will roll over on food safety again and again. 

 

If you operate under a food safety standard and they find out what your doing (without performing a HACCP plan review and somehow reclassifying the risk as not CCP required) they will most likely pull your certification.

 

Yes your boss is your boss but I'd rather have no job than know I'm willingly putting hundreds/thousands/millions of people at risk. 

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#1 mnikodemus

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Posted 29 April 2014 - 06:36 PM

Hello IFSQN Forum,

 

We have the metal detector as our only critical control point at our facility. We have seen an increase in sales and are increasing our number of production lines as a result.

 

The problem is that we haven't gotten our new metal detector in yet, it is still 6 weeks out.

 

Is it possible to temporarily bypass a critical control point if it is approved by management and the HACCP Team?

 

In other words, if we state that we are aware of the risk associated with bypassing this step and approve it by management will we have issues from 3rd party audits (Customer, Governmental, GFSI) ?

 

Thanks for any advice on this!

 

Regards,

 

Michael


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#2 Mr. Incognito

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Posted 29 April 2014 - 07:53 PM

If you put something at a risk category high enough to warrant a CCP there is no way you are going to be able to convince an auditor it was ok to temporarily disregard food safety for sales volume.

 

You've already identified this hazard to be something that is going to cause injury or illness in the absence of its control... and now you want to have product roll through without the control.

 

If you do this your auditor is going to believe, no matter how much you try to explain it to him, that food safety is a second thought to your management.

 

I highly suggest you don't do this.


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#3 alisher

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Posted 29 April 2014 - 08:20 PM

Critical Control Point is called with this name for a reason and you have to hold everything if you bypass CCP.


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#4 mnikodemus

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Posted 29 April 2014 - 08:23 PM

Mr. Incognito,

 

I must say I completely agree with you and this is exactly what I told my boss. He does not agree however and thinks we can get away with it as long as we "are aware of the risk" and demonstrate this to the auditor. Unfortunately I cannot override my boss in this.

 

Would we be able to downgrade the CCP to just a control point based on a risk likelihood of "low". We could justify this by proving that there were no customer complaints about metal in our product ever since we've started tracking them?

 

Thanks,

 

Michael


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#5 Snookie

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Posted 29 April 2014 - 08:49 PM

 

 

In other words, if we state that we are aware of the risk associated with bypassing this step and approve it by management will we have issues from 3rd party audits (Customer, Governmental, GFSI) ?

 

 

 

 

Most likely yes.  Downgrading it to a CP is going to look like exactly what it is.....being able to run without the metal detector and lack of customer complaints is not usually a good defense.  While there may be processes where metal is not a high risk....reality is customers, regulators often want to see the metal detector as a CCP. 

 

Being aware of the risk and preventing the risk are not the same things especially if there is a risk of sharp metal.  The metal detector is a safeguard against metal in your product. What will it cost if someone gets hurt or a customer is lost. 


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#6 Charles.C

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Posted 29 April 2014 - 09:57 PM

Would we be able to downgrade the CCP to just a control point based on a risk likelihood of "low". We could justify this by proving that there were no customer complaints about metal in our product ever since we've started tracking them?

 

Avoiding a metal detector step being a CCP is possible but  you will likely need an eloquent validation/argument to support it since many auditors will automatically (eg as per Codex Tree) consider it a CCP.

 

Another potential  "haccp" objection is that if you have zero CCPs, it can be argued that there is no haccp plan and this can create a new problem depending on yr product/process/location.

 

The general  topic has occurred previously on this forum, eg -

http://www.ifsqn.com...ccp/#entry45694

 

The available options are inevitably relevant to yr actual process, eg an existing meat grinder step is likely to hinder attempts to claim that the risk of metallic contamination is negligible. Just from known experiences. (Unless you can provide a published counter-example which i think does exist from memory of a previous thread here).

 

Some possibilities -

 

(1) A simple risk analysis proposal as you propose is possible although i predict you will need more actual process data to support it. For example see the numerical procedure described in the  Codex 2008 validation reference document below. Visual evaluation has also been done/referenced but more frequently to justify a total lack of a metal detector.

Attached File  codex validation 2008.pdf   206.72KB   60 downloads

 

(2) Another conceptual variation previously discussed is  where the metal detector is envisaged as a monitoring device for a previous CCP, eg a sieve (similar to Codex example in [1]) or to validate a (claimed) visual low risk assessment (an obvious zigzag but desperate times......). Again it relates to yr process.

 

(3) Classification of a MD function within prerequisites. For example see this Kraft approach -

Attached File  Role of Prerequisite Programs.ppt   96KB   64 downloads

 

Rgds / Charles.C

 

PS - added - Are you certain that yr original risk assessment for significant metal hazard was correct anyway ?

(or perhaps the company ordered the MD on this basis so no way to change it now for job security :smile:  )


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Charles.C


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#7 Mr. Incognito

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Posted 30 April 2014 - 11:37 AM

Mr. Incognito,

 

I must say I completely agree with you and this is exactly what I told my boss. He does not agree however and thinks we can get away with it as long as we "are aware of the risk" and demonstrate this to the auditor. Unfortunately I cannot override my boss in this.

 

Would we be able to downgrade the CCP to just a control point based on a risk likelihood of "low". We could justify this by proving that there were no customer complaints about metal in our product ever since we've started tracking them?

 

Thanks,

 

Michael

 

Depending on the circumstances this is not always true.

 

Is there a food safety team and is your boss in charge of it?  Are you under a food safety standard?

 

If the "boss" isn't on the food safety team or isn't in charge of it then you could trump him with the food safety team saying that the risk to the consumer is too high without the CCP. 

 

You could do an annual review of your HACCP system and you could downgrade it to a CP but like Simon said... Good luck lol.

 

A lot of times the quality department is put between a rock and a hard place.  Sometimes you have to just politely argue loudly...

 

Write up a letter saying that you were against this action and that the "Boss's Title" being the responsible party overriding the quality department's council is fully responsible for any and all injuries that may happen as a result of not properly following the HACCP plan and have him sign it... lol


Edited by Mr. Incognito, 30 April 2014 - 11:38 AM.

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#8 cazyncymru

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Posted 30 April 2014 - 02:57 PM

I'm not sure where on "Earth" you are, but I'd love to hear your bosses due diligence defence if someone were to get hurt or die because they decided to by pass a CCP

 

If he does decide to go ahead regardless, make damned sure you put your objections in writing, and you keep a copy of it! (not that it's much use in a due diligence defence)

 

If I'm truthful, if my boss did that to me, then I would no longer want to work for him and I'd be gone at the first opportunity.

 

Caz x


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#9 Mr. Incognito

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Posted 30 April 2014 - 03:11 PM   Best Answer

I agree with Caz.

 

Michael this is some really serious stuff... people go to jail for massive illness or injury incidents especially when it is something they do blatantly and they knew that it could cause illness or injury.  If you have a piece of equipment break down enough to spread metal fragments throughout your product stream that isn't picked up at a CP or found by quality and if it ends up in the body of consumers you may find yourself without a job (company closes due to major recall/injuries) or in jail.

 

In the very least I would:

if you have a food safety team convene a meeting of it and make sure that the meeting minutes show that you brought up that injury to consumers downstream of your process is likely, which is the definition of what a CCP stops, and that you are completely against this. 

 

Better yet:

Find a new job... before they do this.  If they are disregarding food safety this strongly they will do it again.  And even worse if you roll over on this issue now they will know you will roll over on food safety again and again. 

 

If you operate under a food safety standard and they find out what your doing (without performing a HACCP plan review and somehow reclassifying the risk as not CCP required) they will most likely pull your certification.

 

Yes your boss is your boss but I'd rather have no job than know I'm willingly putting hundreds/thousands/millions of people at risk. 


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#10 Scullerdude

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Posted 30 April 2014 - 04:02 PM

Hi Michael,
I completely agree with the other respondents on this. Perhaps some appropriate press cuttings of injuries & legal outcomes might help convince your Boss of his folly?
Kind regards


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#11 Setanta

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Posted 30 April 2014 - 04:38 PM

Do you have on-site inspection? USDA/FDA or something similiar? Maybe a side-bar conversation with your inspector could also convince management of their folly.


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#12 mnikodemus

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Posted 30 April 2014 - 05:15 PM

Thank you for all the great replies here, they were very helpful.

 

I had a second discussion with my boss and highlighted the risk factors yet again, using Mr. Incognito's helpful examples to put things into perspective.

 

I convinced him to lease another metal detector ASAP which should come in at the end of this week. In order to keep production up, we will attempt to run 2 products through the same detector. They are very similar products so the product profiles should align well enough to not hinder metal detection.

 

If this will not work I will propose a system of racking one product, and running the other through the detector, then switch periodically.

 

Again, thank you for your great responses, I'm glad I found this forum.

 

Michael


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#13 Mr. Incognito

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Posted 30 April 2014 - 05:32 PM

Excellent!  I'm happy we were able to help you convince your boss and that's a great idea on how to go with the ramped up production.


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#14 Prudence

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Posted 30 April 2014 - 07:48 PM

Charles C is spot on - most auditors (and customers) ae wedded to metal detection as a CCP - and a lot of the time; they're wrong!

 

Critical Control Point (CCP): A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

 

In many products, a metal detector will not consistenty pick up a needle - in which case, metal detection does not eliminate or reduce the hazard.

 

As a consumer (preferably not of needles) I hope you have other processes in place (preventative maintainance?) to avoid the risk of metal in your product. But even if you could demonstate that, the auditor (and your customer) would still want metal detection - I think it's called a sense of 'false security'......


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#15 Barrie@RJT

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Posted 06 May 2014 - 10:27 AM

 

Charles C is spot on - most auditors (and customers) ae wedded to metal detection as a CCP - and a lot of the time; they're wrong!

 

Critical Control Point (CCP): A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

 

In many products, a metal detector will not consistenty pick up a needle - in which case, metal detection does not eliminate or reduce the hazard.

 

As a consumer (preferably not of needles) I hope you have other processes in place (preventative maintainance?) to avoid the risk of metal in your product. But even if you could demonstate that, the auditor (and your customer) would still want metal detection - I think it's called a sense of 'false security'......

 

 

I agree.

 

We treat our MD as an Operational Prerequisite for that very reason, and we have additional (arguably more effective) controls in place such as knife/blade/saw/chainmail checks documented.  I certainly wouldn't want to rely on our fairly ancient MD as a CCP - it wouldn't pick up a missing chainmail link, for instance, so a visual check is likely to be more effective if there's a problem.


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#16 Mr. Incognito

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Posted 06 May 2014 - 01:13 PM

If your metal detector is so weak it can't detect a standard piece of metal you may need to have some in depth maintenance done on it and a good calibration.  If it's that bad why is it even in your system if you have no faith in its ability to do its job?

 

Typically metal detectors are calibrated to detect metal as small as 1.5 - 2.0 mm inside of the product being checked.  Yes metal detectors have inherent issues like weak spots but they should be able to do their job properly.  Would you keep ordering/using knives that cut the product only 1/2 of the time?

 

Some plans justify a metal detector as a CP or oPRP and that can be fine depending on the circumstances but his is not classified that way.  To just suggest that they had no clue what they were doing without looking at their system and plan is a curious way to give advice.  Instead of doing that expect they did their job and were trained on how to perform a proper HACCP analysis and explain to them what is going to happen if they decide to disregard the plan they put together.  It's better to have a metal detector that should be a CP labeled as a CCP than have one that should have been a CCP as a CP. At this point they have only a few options:

 

1) Disregard their own HACCP plan which can result in jail sentence in the worst scenario.

2) Perform their annual HACCP verification and decide with all of the information and evidence that they don't require it to be a CCP and downgrade it properly but have to be able to back up their decision to an auditor.  If they did it wrong it could end the same as #1.

3) Not increase production because they don't want to do the first 2.

4) Rent a metal detector until their new one comes in.

 

I think they came to the proper conclusion.  Not to disregard their HACCP plan and find another way around the situation.  Of course they will need to check the metal detector to make sure it can detect the proper size of metal so it still stays within their HACCP plan but it's going to be a lot better for them to temporarily use, with the food safety team's agreement, a rented metal detector than to disregard the one they have.


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#17 Snookie

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Posted 07 May 2014 - 09:41 PM

 

Charles C is spot on - most auditors (and customers) ae wedded to metal detection as a CCP - and a lot of the time; they're wrong!

 

Critical Control Point (CCP): A step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

 

In many products, a metal detector will not consistenty pick up a needle - in which case, metal detection does not eliminate or reduce the hazard.

 

As a consumer (preferably not of needles) I hope you have other processes in place (preventative maintainance?) to avoid the risk of metal in your product. But even if you could demonstate that, the auditor (and your customer) would still want metal detection - I think it's called a sense of 'false security'......

 

 

 

 

If your metal detector is so weak it can't detect a standard piece of metal you may need to have some in depth maintenance done on it and a good calibration.  If it's that bad why is it even in your system if you have no faith in its ability to do its job?

 

Typically metal detectors are calibrated to detect metal as small as 1.5 - 2.0 mm inside of the product being checked.  Yes metal detectors have inherent issues like weak spots but they should be able to do their job properly.  Would you keep ordering/using knives that cut the product only 1/2 of the time?

 

 

Present conversation aside......Prudence makes a good point.  Most view metal detectors much like what Mr. Incognito said above, however they are not that simple.  Many high quality properly designed and calibrated detectors can struggle with certain products.  There are a lot of factors such as aperture, package size and what the product is, how conductive any of the materials are. 

 

When discussing 1.5-2.0 am guessing we are discussing Fe not SS.  In the produce industry, that is the tightest standard and many companies struggle with a high level of false rejects.  Any size to the package makes it nearly impossible.  Detectors are a wonderful tool, but they are not a panacea.  You must always be mindful of their limitations. 


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#18 Mr. Incognito

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Posted 08 May 2014 - 11:13 AM

No our metal detectors detect, in a bag of flour or germ, SS, FE, NF at either 1.5mm or 2.0mm. I'm not sure why they have 2 different sizes.  The pasta factory I worked at where all three were checked at 2.0mm.

 

Without looking at the metal detector sheet I can't say which ones are 1.5mm or 2.0mm but they are all 1.5mm or 2.0mm.

 

The only issues I've seen with false rejects has been in the packaging if there is a small piece of metal in it... so it's not really false. 

 

My point is if you have a metal detector that you have no faith in... you shouldn't have it in the first place.


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#19 cazyncymru

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Posted 08 May 2014 - 12:22 PM

Personally, I'd rather have false rejects that have metal go out to a customer!


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#20 Charles.C

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Posted 08 May 2014 - 12:27 PM

No our metal detectors detect, in a bag of flour or germ, SS, FE, NF at either 1.5mm or 2.0mm. I'm not sure why they have 2 different sizes.  The pasta factory I worked at where all three were checked at 2.0mm.

 

Without looking at the metal detector sheet I can't say which ones are 1.5mm or 2.0mm but they are all 1.5mm or 2.0mm.

 

The only issues I've seen with false rejects has been in the packaging if there is a small piece of metal in it... so it's not really false. 

 

My point is if you have a metal detector that you have no faith in... you shouldn't have it in the first place.

 

Sensitivity depends on various factors like product/process/MD design. Your product/aperture combination was maybe optimum. And possibly the vintage also. :smile:

 

Attached File  MD Sensitivity Table.pdf   187.28KB   47 downloads

 

Rgds / Charles.C


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#21 mnikodemus

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Posted 08 May 2014 - 02:07 PM

At our bakery we use 1.5 mm Ferrious, 2.0 mm Non-Ferrous, 2.5 mm 316 Stainless, 3.5 mm 304 Stainless for hourly checks.
 
The metal detector has been working excellent and in the past we picked up metal objects in the product that could barely be seen with plain eyes. No matter how well your pre-requisite programs are designed, there is still the risk of metal contamination, especially in processing plants with metal conveyors (to pass through ovens, for ex.) and metal sprockets or other metal/metal friction points.
 

I think they came to the proper conclusion.  Not to disregard their HACCP plan and find another way around the situation.  Of course they will need to check the metal detector to make sure it can detect the proper size of metal so it still stays within their HACCP plan but it's going to be a lot better for them to temporarily use, with the food safety team's agreement, a rented metal detector than to disregard the one they have.

 

Mr. Incognito, that's exactly what we ended up doing, we rented a second metal detector for the time being.


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#22 Charles.C

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Posted 08 May 2014 - 04:20 PM

Dear mnikodemus,

 

Seems curious that test piece SS304 > SS316. Thought that usually  304 is easier to detect. eg -

http://www.ifsqn.com...ge-2#entry54852

 

 

Rgds / Charles.C


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Charles.C






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