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Do we need to maintain traceability records for mesh filters?


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#1 TGM2010

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Posted 01 February 2016 - 02:59 PM

Hi,

 

We use mesh filters for foreign material control in our plant. These are changed at a minimum of once per week. We package a liquid product and I was wondering if we are supposed to maintain traceability records for the filetrs since the filters come in contact with the food. We have a Letter of Guarantee from the supplier. Is this good enough?

 

TGM


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#2 JohnWheat

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Posted 01 February 2016 - 03:10 PM

I would keep traceability records. I would also (is possible) check for damage etc start and end of production as a minimum.

We use replaceable and permanent filters and check that:

A) they're in place and fitted correctly 

B) show no signs of wear or damage that posses a risk to finished product


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#3 Charles.C

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Posted 01 February 2016 - 03:55 PM

Hi,

 

We use mesh filters for foreign material control in our plant. These are changed at a minimum of once per week. We package a liquid product and I was wondering if we are supposed to maintain traceability records for the filetrs since the filters come in contact with the food. We have a Letter of Guarantee from the supplier. Is this good enough?

 

TGM

 

Hi TGM,

 

i assume this is haccp-related query ?

 

Sorry but i don't get it.

 

If you believe that there is a significant risk of the filter contaminating the food, it should be a CCP. 

 

AFAIK, traceability is related to the source/destination of raw materials and finished products ?

 

Not that i have any objection to yr maintaining a maintenance record of the filter.

 

i an curious as to what the Letter of Guarantee refers to ? Suitable for food use ?


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Kind Regards,

 

Charles.C


#4 Lelouch_rayne

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Posted 02 February 2016 - 12:15 AM

I agree with Charles  :sleazy: .

 

Something like filters replacement is not necessarily to be part of traceability. Since traceability generally refers your ability to track raw material inputs to finished product output (meaning it mostly talks about raw materials).

 

So, in your case, the filters could be a part of your pre-operational checklist if you badly want to check and keep record of it. The frequency and lot codes and other manufacturing details of your filters could be noted in their so that you can keep track of them. 

 

 

 

Sincerely,

 

Joan


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#5 QAGB

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Posted 02 February 2016 - 01:34 PM

Hi TGM,

 

i assume this is haccp-related query ?

 

Sorry but i don't get it.

 

If you believe that there is a significant risk of the filter contaminating the food, it should be a CCP. 

 

AFAIK, traceability is related to the source/destination of raw materials and finished products ?

 

Not that i have any objection to yr maintaining a maintenance record of the filter.

 

i an curious as to what the Letter of Guarantee refers to ? Suitable for food use ?

 

 

I agree with Charles  :sleazy: .

 

Something like filters replacement is not necessarily to be part of traceability. Since traceability generally refers your ability to track raw material inputs to finished product output (meaning it mostly talks about raw materials).

 

So, in your case, the filters could be a part of your pre-operational checklist if you badly want to check and keep record of it. The frequency and lot codes and other manufacturing details of your filters could be noted in their so that you can keep track of them. 

 

 

 

Sincerely,

 

Joan

 

 

Hi TGM2010,

 

I also don't know why you would necessarily need the filter manufacturing information for traceability. The desired result is that you can trace your product before and after the filter in case you have holes/damage or foreign material in your filter. I don't see what the Letter of Guarantee could do for you at that point.

 

You should have a document in place that details your filter checks, however. Auditors want to see that the filters are being checked and what sorts of results you are obtaining from those checks. That serves as part of your traceability system.

 

I would also suggest to you - as JohnWheat explains in his post (only a suggestion), that you check your filters more than once per week, especially if you are running daily. If you check your filters at the end of the week, and something happens to the filter or you find foreign material, you're looking at holding and possibly recalling a week's worth of product (however long it has been since the last good check).

 

QAGB


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#6 alvindman

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Posted 02 February 2016 - 01:42 PM

I understand that you consider the filter as a food contact material. I assume that you want traceability so in case the supplier notify you about potential risk involving their filters you can identify which products came contact with a particular batch of filters. If this is the intent, then IMO you should keep records/traceability of the filters used every production run. 


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#7 QAGB

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Posted 02 February 2016 - 01:56 PM

I understand that you consider the filter as a food contact material. I assume that you want traceability so in case the supplier notify you about potential risk involving their filters you can identify which products came contact with a particular batch of filters. If this is the intent, then IMO you should keep records/traceability of the filters used every production run. 

 

Hi Alvindman,

 

That's a valid point. I never thought about it that way. TGM2010 may want to ask for a Certificate of Compliance rather than a Letter of Guarantee which should state the important coding information, in case something does happen and the supplier notifies the company of a potential problem with the filters.

 

I've never been asked for such a record, but that is food for thought....

 

QAGB


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#8 Charles.C

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Posted 02 February 2016 - 02:54 PM

I understand that you consider the filter as a food contact material. I assume that you want traceability so in case the supplier notify you about potential risk involving their filters you can identify which products came contact with a particular batch of filters. If this is the intent, then IMO you should keep records/traceability of the filters used every production run. 

 

Hi alvindman,

 

The point is that this is not haccp traceability.

 

Interesting comment nonetheless.

 

i suppose an engineering store using FIFO ( :closedeyes: ) would also document the same information.


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Kind Regards,

 

Charles.C


#9 TGM2010

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Posted 02 February 2016 - 06:39 PM

 What Alvindman stated is what I was asking.  SQF requires us to be able to trace the product; packaging; ingredients and processing aids. Filters do not fall into any of these categories but they come in direct contact with the food and they are changed at least once per week.

 

I guess having a certificate of conformance as mentioned by QAGB is the best way to go.

 

Thank you!


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#10 Charles.C

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Posted 03 February 2016 - 06:05 AM

 What Alvindman stated is what I was asking.  SQF requires us to be able to trace the product; packaging; ingredients and processing aids. Filters do not fall into any of these categories but they come in direct contact with the food and they are changed at least once per week.

 

I guess having a certificate of conformance as mentioned by QAGB is the best way to go.

 

Thank you!

 

Hi TGM,

 

Thanks for yr information that the context is SQF Food Standard.

 

In view of yr concern over the mesh filter "traceability"  I suggest two options –

 

(1) Include the Mesh Filter “Maintenance” within SQF Prerequisite Programs as per Para.11.2.9.1 (or perhaps 11.2.12.1). This would allow inclusion of  yr specific requirement to fully document  any changes of  filter and simultaneously avoid possible confusion over the terminology “traceability” (“trace”) as elsewhere used in the SQF Standard.

 

(2) If you consider the step where food is in contact with the mesh filter as being a significant process hazard, it should of course be included as a CCP as per my post 3. This would, I guess, be handled via Sec. 2.4.3.1.

You could include a “box”  requiring insertion of the filter code in the Record  form for routine monitoring of the filter condition. Additionally, you could, if felt necessary, add a 2nd Form to specifically Record changes in the Filter, to be counter-signed by the maintenance engineer. This would again avoid possible “traceability” terminology confusions.


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Kind Regards,

 

Charles.C


#11 alvindman

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Posted 03 February 2016 - 10:49 AM

Hi alvindman,

 

The point is that this is not haccp traceability.

 

Interesting comment nonetheless.

 

i suppose an engineering store using FIFO ( :closedeyes: ) would also document the same information.

 

That is right.


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#12 CMHeywood

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Posted 03 February 2016 - 05:21 PM

My opinion is that you should have "traceability" for anything that could contaminate your product.  Can you track which lot of mesh filters were used during a certain period?


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