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Metal detection identified in the process flow

BRC Metal detector Process flow

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#1 LoredanaM

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Posted 16 June 2014 - 09:35 PM

Hello all.

 

I am in search of an advice or suggestion. My company, the plant where I am working now, is going to have the first BRC certification in a week (hence mine first one too).

 

We just installed a metal detector, and though it doesn't specify in the HACCP plan when the product in the process flow needs to be tested, in the flow diagram it is after packaging (I am new in my position with this company, like one month).

 

The company is packaging raw fish, to be cooked: we do cut the fish, debone it or portion it. Because of floor plan, we decided to test the product for metal inclusion after it is cut and debone and prior to be packaged. I have to mention that we do have a sharps daily inventory inspection, which would be used as a back-up plan if the metal detector is not working properly.

 

If anyone has a BRC experience similar to mine, can you let me know if that is acceptable for the auditor, or if I have to insist on moving the metal detector after the fish is packed.

 

I appreciate your help,

 

Thank you


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#2 Snookie

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Posted 16 June 2014 - 10:36 PM

This is not a BRC question as much as it is a HACCP question.  In the process you place the metal detector in the last possible place after the possibility of metal getting into the package.  Very often it is after the product is packaged and before it goes in the box.  But that is not an absolute.  You need to be able to justify that wherever the metal detector is in the process there is no possibility of metal intrusion.  Otherwise it is in the wrong part of the process. 


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#3 Tomato

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Posted 16 June 2014 - 11:06 PM

Who made the flow diagram? And I would put the MD after the packaging because it will have a better chance to catch any FM.


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#4 joelchenda

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Posted 17 June 2014 - 09:04 AM

We are about to install a MD. After conducting a analysis on metal inclusion, we idenfied that the most likely contamination is during cutting portions [cutting blades and knives] and injection [injector needles] in the packing section. So we have placed the MD after packaging in our flow diagram.


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#5 Mr. Incognito

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Posted 17 June 2014 - 11:18 AM

It is best, if possible, to metal detect after the product is sealed in its primary packaging.  The reasoning for this is that if a bolt, nut, etc falls onto the product or into the primary food contact packaging it will be a foreign material complaint and a possible, depending on the product, consumer safety hazard.

 

So for pasta we put it after the cartoner (the carton was the primary food contact packaging) but before the case packer (the case was secondary packaging).  On bags of pasta we did it after the bagger and before the case packer.  In yogurt we couldn't do it because we had foil seals (ok we could but we wouldn't be able to test for non-ferrous because of the foil so they didn't see the point... I did but I didn't matter).  In flour bagging we have it right after the bagger and there is no secondary packaging.

 

So... for you how is the fish packaged?  Is it in a plastic or film pack or is it boxed?


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#6 fgjuadi

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Posted 17 June 2014 - 11:41 AM

In the process you place the metal detector in the last possible place

 

 

It is best, if possible, to metal detect after the product is sealed in its primary packaging. 

Agreed, after packaging so long as packaging isn't metal / can fit through the detector.  Last possible place.


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#7 Mr. Incognito

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Posted 17 June 2014 - 11:47 AM

Agreed, after packaging so long as packaging isn't metal / can fit through the detector.  Last possible place.

 

I agree for the most part.

 

You don't want to do it after secondary packaging, like a case of cartons, if it is recycled material at all otherwise you may get kickoffs based on metal in the packaging.  We used recycled cardboard as a secondary package and if it had metal in it then it would reject.  This is why you only want to do it after primary food contact packaging.  There is always a possibility of having metal in your packaging if your packaging supplier has metal that gets into the packaging but it is less of a chance if you have less packaging in the detector.

 

Also you do have to make sure the density of what your testing is... if it's a case of cartons it my detect different than just a carton of product.  But for that it's more important to make sure your equipment manufacturer knows what your testing and can assure that the machine will perform to your expectations.


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#8 Aloysius

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Posted 17 June 2014 - 01:08 PM

I agree with most of what is said. Just to add, any metal detector checking on a final packaged product either in primary or secondary packaging the sensitivity of such metal detectors are quite wide.
Location of metal detector will be directly be the result of the Risk Assessment & degree of the Hazard.


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#9 LoredanaM

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Posted 17 June 2014 - 01:44 PM

It is best, if possible, to metal detect after the product is sealed in its primary packaging.  The reasoning for this is that if a bolt, nut, etc falls onto the product or into the primary food contact packaging it will be a foreign material complaint and a possible, depending on the product, consumer safety hazard.

 

So for pasta we put it after the cartoner (the carton was the primary food contact packaging) but before the case packer (the case was secondary packaging).  On bags of pasta we did it after the bagger and before the case packer.  In yogurt we couldn't do it because we had foil seals (ok we could but we wouldn't be able to test for non-ferrous because of the foil so they didn't see the point... I did but I didn't matter).  In flour bagging we have it right after the bagger and there is no secondary packaging.

 

So... for you how is the fish packaged?  Is it in a plastic or film pack or is it boxed?

The product goes first in a plastic bag, and then into a case/box carton or Styrofoam. My issue here is that all packaging is per order and there is little to none consistency in the final product ( same product, weight). We do not use any type of equipment for packaging, it's all done manual ( just use the sale to weigh).


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#10 LoredanaM

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Posted 17 June 2014 - 01:49 PM

I agree for the most part.

 

You don't want to do it after secondary packaging, like a case of cartons, if it is recycled material at all otherwise you may get kickoffs based on metal in the packaging.  We used recycled cardboard as a secondary package and if it had metal in it then it would reject.  This is why you only want to do it after primary food contact packaging.  There is always a possibility of having metal in your packaging if your packaging supplier has metal that gets into the packaging but it is less of a chance if you have less packaging in the detector.

 

Also you do have to make sure the density of what your testing is... if it's a case of cartons it my detect different than just a carton of product.  But for that it's more important to make sure your equipment manufacturer knows what your testing and can assure that the machine will perform to your expectations.

Sensitivity is another issue - due to packaging different type of fish together in a case (each in its individual bag) and it varies from one case to another, it is almost impossible to create a program that will make it feasible for the packaging process. It can be done by auto-setup, but it will have to be done for each single case. Business wise it is going to cost time and in the last 20 years this facility has never had a metal contamination.

 

And yes the carton can have metal in it if it's the recyclable one - already have that experience.


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#11 LoredanaM

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Posted 17 June 2014 - 01:53 PM

We are about to install a MD. After conducting a analysis on metal inclusion, we idenfied that the most likely contamination is during cutting portions [cutting blades and knives] and injection [injector needles] in the packing section. So we have placed the MD after packaging in our flow diagram.

all we have in the process are the cutting knives and the deboning equipment. So, once this process step is accomplished, we pre-packed it and run it through the metal detector. Once is passed it goes directly to the packaging table (like 10 feet distance from the metal detector). The packaging is done manually, no equipment involved.


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#12 Mr. Incognito

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Posted 17 June 2014 - 01:54 PM

Well... I don't know that I believe that the sensitivity of the metal detector will be significantly affected if you have different cuts of fish in the same package... I mean yeah density will be a little different here and there but generally I'm not sure that would be a show stopper.  Now if you were asking about a checkweigher I'd completely agree.

 

Like I said talk to different manufacturers and see if you can find a product that will metal detect for you properly in the industry you are in. 

 

Food safety, just as in safety, is not a knee jerk process anymore.  It's not about what we've done for 20 years but making sure we don't in the next 20 years.  You can't say "We haven't so we don't need to"  You need to say "What are the potential risks to human health and safety and how can we properly mitigate them."


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#13 LoredanaM

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Posted 18 June 2014 - 02:33 PM

Well... I don't know that I believe that the sensitivity of the metal detector will be significantly affected if you have different cuts of fish in the same package... I mean yeah density will be a little different here and there but generally I'm not sure that would be a show stopper.  Now if you were asking about a checkweigher I'd completely agree.

 

Like I said talk to different manufacturers and see if you can find a product that will metal detect for you properly in the industry you are in. 

 

Food safety, just as in safety, is not a knee jerk process anymore.  It's not about what we've done for 20 years but making sure we don't in the next 20 years.  You can't say "We haven't so we don't need to"  You need to say "What are the potential risks to human health and safety and how can we properly mitigate them."

I didn't intend to make it sound like I do not value the importance of food safety and go with "if it didn't happen it will not" - I am actually pretty strict about it. It just I came into a process already put in place and the metal detector was already purchased. All I am trying to figure out is how to make the best out of the situation and provide customers with a safe product.

 

Thank you all for your help :)


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#14 Charles.C

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Posted 18 June 2014 - 03:57 PM

Dear Loredana,

 

is it frozen BF/IQF/glazed before final packing or  ? The MD sensitivity relates to the food matrix and other factors frequently discussed here, eg aperture size (ie packing unit dimensions).

 

IMEX the sharps check will initiate an auditor debate if proposed as a backup. Spare MD is recommended, eg second-hand if finance an issue.

 

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#15 Snookie

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Posted 18 June 2014 - 03:58 PM

You may want to have the company who sold you the machine or the manufacturer (if it was not new when purchased) come out and set the machine up and work with you.  Different package sizes, different moisture content can have an effect.  If the machine was new when purchased this is usually included in the price.  This way when BRC looks at this you have the MD company behind you as the expert. 

 

Also if this is new equipment (or at least for your company) or a equipment is in a different location, it will need to be validated by a professional at start up and then re-certified annually. 


Edited by Snookie, 18 June 2014 - 04:11 PM.

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#16 Avila

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Posted 18 June 2014 - 04:12 PM

In frozen block Surimi plant, i put MD before secondary packaging step


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#17 LoredanaM

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Posted 18 June 2014 - 06:06 PM

Dear Loredana,

 

is it frozen BF/IQF/glazed before final packing or  ? The MD sensitivity relates to the food matrix and other factors frequently discussed here, eg aperture size (ie packing unit dimensions).

 

IMEX the sharps check will initiate an auditor debate if proposed as a backup. Spare MD is recommended, eg second-hand if finance an issue.

 

Rgds / Charles.C

The fish is sold bulk raw or frozen; all packaged produce is delivered to a warehouse and from there to stores - and all produce is To Be Cooked; anything that we have RTE is received in and shipped out in the same package ( box in - box out).

 

The MD was just installed, hence not by a certified technician, and I mentioned that to the upper management. The MD is a CCP in the process and I know that as a CCP the equipment has to be calibrated by a certified technician. Like I mentioned earlier, I am just a month old in this position with this company, and the decisions were made prior to my arrival; all I can do now (the audit is next week) is to work with what I have and make the best out of it.


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#18 LoredanaM

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Posted 18 June 2014 - 06:08 PM

You may want to have the company who sold you the machine or the manufacturer (if it was not new when purchased) come out and set the machine up and work with you.  Different package sizes, different moisture content can have an effect.  If the machine was new when purchased this is usually included in the price.  This way when BRC looks at this you have the MD company behind you as the expert. 

 

Also if this is new equipment (or at least for your company) or a equipment is in a different location, it will need to be validated by a professional at start up and then re-certified annually. 

The company has 3 locations and two of them got already certified - we are all using the same type of MD and I am not aware that they had any type of certified technicians installing the equipment; if they did it hasn't happened here. I am aware of all the issues that this installing procedure pose.


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#19 LoredanaM

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Posted 18 June 2014 - 06:09 PM

In frozen block Surimi plant, i put MD before secondary packaging step

That is mainly how it is set up in my plant too.


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#20 Snookie

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Posted 18 June 2014 - 08:35 PM

 all I can do now (the audit is next week) is to work with what I have and make the best out of it.

 

Good Luck and let us know how it goes. 


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#21 Tony-C

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Posted 19 June 2014 - 02:15 PM

From BRC Guidance 4.10.1.2:
Equipment should be placed as close to the end of the production process as is practical, so that the whole process (including packing lines) is protected.

 

Regards,

 

Tony


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#22 LoredanaM

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Posted 26 June 2014 - 03:30 PM

I want to thank you all for your help and yesterday the audit was concluded and we are recommended by the auditor to receive 'A' grade - we had like 8 minors. It was a stressful 5 weeks but we made it :)


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#23 Mr. Incognito

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Posted 26 June 2014 - 03:53 PM

Congratulations! It's great to hear you passed with an A grade.  :doctor:


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#24 Snookie

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Posted 26 June 2014 - 03:54 PM

Congratulations and well done!!!


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#25 Avila

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Posted 26 June 2014 - 03:54 PM

Good job and congratulation :thumbup:


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