12 replies to this topic

[Whitney]

Hi

 

I wonder if someone can help? We have a HACCP system in place and metal detection is a CCP. In the control chart there is a risk assessment at each process step for any hazards identified at that step. In the metal detection step the risk rating is high and therefore goes through the decision tree and comes out as a CCP. Does this cover this section (4.10.1.1) or is a different separate risk assessment required? I am struggling as it says 'in association with the HACCP study'.

 

Any help is appreciated.

 

Thanks

 

Whitney

[Nidhi Arora Khare]

Hi

 

I wonder if someone can help? We have a HACCP system in place and metal detection is a CCP. In the control chart there is a risk assessment at each process step for any hazards identified at that step. In the metal detection step the risk rating is high and therefore goes through the decision tree and comes out as a CCP. Does this cover this section (4.10.1.1) or is a different separate risk assessment required? I am struggling as it says 'in association with the HACCP study'.

 

Any help is appreciated.

 

Thanks

 

Whitney

Hi Whitney,

Metal detection is a step in your manufacturing process and the same is evaluated to be identified as CCP. There is no separate risk assessment required for the same. 

Rgds,

Nidhi

[Whitney]

Hi Nidhi

 

When I read the clause, to me it is saying a documented assessment shall be carried out to identify the potential use of equipment to detect or remove foreign bodies. So the assessment should identify which piece of equipment should be used.

 

The risk assessment I refer to above isn't to determine the potential use its to determine whether the foreign body detection equipment we have in place (metal detection) is a CCP or not. I just wonder whether we are missing the initial assessment which determines which foreign body equipment is required?

 

I don't know if I am interpreting the wording wrong but its the section where it states 'to identify the potential use'.

 

hope this makes sense?

 

thanks

 

Whitney

[Nidhi Arora Khare]

Hi Whitey,

 

For a instance, let us forget about metal detector and consider it only as a process step (if the same is listed so in your HACCP flow chart).

The clause says "a documented assessment shall be carried out to identify the potential use of equipment to detect or remove foreign bodies. So the assessment should identify which piece of equipment should be used."

I suppose, the HACCP team to identify potential Hazards (Physical/ Chemical/ Biological) and then determine if the same are getting controlled with any available PRPs or equipment installed in product processing cycle. Here, if there is a identified physical hazard of thread or metal piece, then the control measure for the same needs to be identified i.e. Sieve for thread & Metal detector for metal pieces. 

If your process do not identify any hazards related to metal piece, in that case Metal detector though installed as a equipment in the processing cycle, do not require to be identified as CCP and for other possible Physical hazards, control measure (in the form of equipment or process) needs to be implemented.

Identification of CCP in your process shall completely depend on the type of hazard identified during product processing cycle and the control measures required to prevent, eliminate or reduce it to acceptable (critical) levels.

 

Hope this helps.

 

Rgds,

Nidhi

[tahlyav]

Foreign-Body Contamination could be more than just metal. If you have potential for other types of foreign body contamination such as: bones, stones, glass/ brittle plastic, there may be other removal systems to consider. If metal is the only foreign body hazard you have identified in your process, then I would say you are covering the requirement. 

[Whitney]

thank you for your response. I think I understand.

 

in the process steps we have identified physical hazards including metal but we haven't put metal detection down as a control as the view we have is that metal detection does not control the hazards, it simply identifies them and reduces to an acceptable level. we have controls in place at each step, such as start up checks etc which in our view prevent the hazards and therefore controls them. Metal detection is only mentioned as a process step and its the issue of it failing that has made it be high risk and go through the tree and is a CCP due to the step being specifically designed to eliminate or reduce to an acceptable level. Is this wrong?

 

Also rom your comments above should I be putting metal detection in as a control along side start up checks etc at all steps where metal has been identified as a potential hazard?

 

thanks

[Whitney]

Hi Everyone

 

I am still struggling with this clause. is there a separate risk assessment required for this clause? Please can anyone provide me with a copy of their risk assessment that covers this section?

 

Many thanks

W

[Tony-C]

I think tahlyav has answered your question.

 

Potential hazards, and the sources of those hazards, must be identified so that appropriate control procedures can be put in place to minimise the likelihood of product contamination.

 

Examples of foreign bodies include:

Glass
Wood
Stones

Fruit stones
Metal
Insulation
Bone
Plastic
Personal effects

 

You will need to consider the likelihood of these ending up in the product, their likely source and consider the potential use of equipment to detect or remove foreign-body contamination. Such equipment includes:

filters
sieves
metal detection
magnets
optical sorting equipment
X-ray detection equipment
other physical separation equipment

 

So for example if I am making cherry pie filling, there is a potential for stones to be in the filling. Based on history you may decide that there is a high risk of stone being present. You would then consider the best option or options to reduce this risk (to an acceptable level). In this case you might decide that something like a 7mm sieve is the best option not a metal detector (&rejection unit).

 

This is how the assessment required is different from your original post.

 

Kind regards,

 

Tony

[Whitney]

Thank you Tony for your thorough response. Just to clarify, this would be a stand alone risk assessment not the risk assessment in the hazard analysis in HACCP?

 

Many thanks

 

Whitney

[Tony-C]

Hi Whitney,

 

The standard states that the assessment is 'in association with the HACCP study shall be carried out on each production process to identify the potential use of equipment to detect or remove foreign-body contamination.'

 

​​I normally use an excel spreadsheet for my assessment. For ease of demonstrating compliance I would filter the foreign body hazards identified in this spreadsheet and use it as a supplement with additional assessment to demonstrate that you have considered the risk of these foreign body hazards and available recognised controls and justify why they are there in your process or not.

 

Kind regards,

 

Tony

[Charles.C]

Thank you Tony for your thorough response. Just to clarify, this would be a stand alone risk assessment not the risk assessment in the hazard analysis in HACCP?

 

Many thanks

 

Whitney

 

An excellent question. Difficult to see IMO why the HACCP plan/hazard analysis should not cover 4.10.1.1 but the peculiar statement "A documented assessment in association with the HACCP study" tends to suggest the opposite.

 

I assumed this was just another BRC PITA/lever to promote the BRC Interpretation Guidance which presumably clarifies the convolutions.

[Dan E]

Sorry for replying to such an old thread, but I thought I could add some context based on my recent experience with this particular matter.

 

During my most recent audit, I received a non-conformity for 4.10.1.1 because "no documented assessment was available for review". I have an extensive hazard analysis but the auditor claimed that the analysis for this section was supposed to be an assessment of the effectiveness of the hazard analysis controls, and that it was separate. He said we should be reviewing the ongoing effectiveness of our controls by assessing trends related to foreign material e.g. if you have a lot of glass related customer complaints, that might indicate you need to install an x-ray, or if you have foreign material complaints of a certain size maybe you need to reevaluate your sifter screen size to catch the foreign material you are missing.

 

To me this seems like a lot to read into based on what the standard claims in 4.10.1.1. The interpretation guide is no help either unfortunately. From the interpretation guide:

 

"The food safety plan should be the starting point for implementing an effective foreign body control programme. Potential hazards and their sources must be identified so that appropriate control procedures can be put in place to minimise the likelihood of product contamination. The Standard lists some of the most common forms of equipment used."

 

Does that not sound like what the hazard analysis is supposed to accomplish? Aren't we already supposed to reassess the hazard analysis at least annually anyways? This just feels redundant to me, and as always with BRC it feels like my auditor has many hidden expectations about what the standard "really" means.

[Tony-C]

Hi Dan E,

 

Thank you for your post, it is always worth hearing what is happening with current audits.

 

This isn’t a new clause and so I’m a bit surprised that it has come up. It does seem a bit harsh to get a non-conformity and for me it would depend on whether there is evidence that you should have assessed data that indicated more robust foreign body removal systems should be in place.

 

The assessment required as per BRCGS Global Satandard for Food Safety Issue 9 Clause 4.10.1.1 is related to potential use of equipment:

 

A documented assessment in association with the food safety plan (see section 2 – The food safety plan) shall be carried out on each production process to identify the potential use of equipment to detect or remove foreign-body contamination.

 

The assessment for 4.10.1.1 can supplement Food Safety Plans by analysis of non-conformances and complaints to see if further measures are warranted.

 

With regards to Hazard Analysis, Clause 2.7.3 states:

The HACCP food safety team shall consider the control measures necessary to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

 

IMO the wording can be interpreted in different ways. If you have considered the control measures necessary to prevent or eliminate a food safety hazard or reduce it to an acceptable level, then is that the same as assessed? Did you consider the potential use of equipment to detect or remove foreign-body contamination as a control measure for physical hazards during the Hazard Analysis?

 

Previously I received a major non-conformance for not having a Metal Detector on the production lines. I successfully appealed against this major non-conformance and justified not having a Metal Detector based on prerequisites in place and a considerable complaint history without a single metal complaint. BRCGS subsequently changed the requirement to:

4.10.3.1 Metal detection equipment shall be in place unless risk assessment demonstrates that this does not improve food safety.

 

If you are not happy then I would suggest that you write to the certification body explain your thoughts and ask for further clarity on the non-conformance and what their expectations were.  If you are still not happy then you could appeal, but if it is the only issue raised then I would probably just move on.

 

Kind regards,

 

Tony

Edited by Tony-C, 20 September 2023 - 04:23 AM.