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#1 cuong0000

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Posted 28 July 2017 - 03:44 AM

Hello Everybody

Our factory are nut processing factory and I'm really confused when decide to carton metal detector is one oPRP : our flowchart have 2 metal detector, one metal detector before packing carton and one after packing carton. So anybody can help to advise is it appropriate if we decide metal detector before packing is CCP , and metal detector after packing is oPRP ?

Please help ... Waiting for reply from everybody.

Thank you so much. 


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#2 Charles.C

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Posted 28 July 2017 - 04:32 AM

Hello Everybody

Our factory are nut processing factory and I'm really confused when decide to carton metal detector is one oPRP : our flowchart have 2 metal detector, one metal detector before packing carton and one after packing carton. So anybody can help to advise is it appropriate if we decide metal detector before packing is CCP , and metal detector after packing is oPRP ?

Please help ... Waiting for reply from everybody.

Thank you so much. 

 

Any choice of oprp/ccp will depend on the criteria you are using.

 

But, offhand, I would have expected the risk assessment (assuming the 2 MD operational sensitivities are comparable [???]) prior to any oprp/ccp evaluation to render the first MD not to be associated with a significant hazard at all, ie neither CCP nor OPRP.

 

In traditional haccp, and again assuming the MD operational sensitivities are comparable (???), it would IMO be conventional to make the 2nd one a CCP and the first one of no particular haccp significance.

 

If the 2 MDs are not of equivalent sensitivity, the answer IMO may change, eg perhaps to a "combined" CCP or other option (I have a suspicion that the 2nd MD may be less efficient than the first one ?).


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Charles.C


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#3 cuong0000

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Posted 28 July 2017 - 07:06 AM

Any choice of oprp/ccp will depend on the criteria you are using.

 

But, offhand, I would have expected the risk assessment (assuming the 2 MD operational sensitivities are comparable [???]) prior to any oprp/ccp evaluation to render the first MD not to be associated with a significant hazard at all, ie neither CCP nor OPRP.

 

In traditional haccp, and again assuming the MD operational sensitivities are comparable (???), it would IMO be conventional to make the 2nd one a CCP and the first one of no particular haccp significance.

 

If the 2 MDs are not of equivalent sensitivity, the answer IMO may change, eg perhaps to a "combined" CCP or other option (I have a suspicion that the 2nd MD may be less efficient than the first one ?).

Dear Mr. Charles

Thank for your advise, your comment very helpful for me. You are right, the 2nd MD( Fe2.5, Non-Fe3.5,Sus 4.0mm) less efficient than 1st MD ( Fe1.5, Non-Fe 1.5,SuS 2.5mm). So in this case, can we decide CCP at 1st MD ?


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#4 Sigrid B

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Posted 28 July 2017 - 09:05 AM

Hello cuong0000,

 

As per standards, CCP is the "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" - personally I take it to mean like a "kill step" or a last step to control an identified hazard.

 

If the 1st MD will be the CCP, I would think that the scoring for physical hazard at the next step is reduced, which may mean that you wouldn't need to undergo the CCP decision tree anymore. I'm assuming that after the first MD, the product is sealed and there is no longer an entry point for contaminants.

 

I'm not sure why the 2nd MD would be an oPRP if that's the case, unless the carton box is a verified source of metal contaminants (based on historical records)?


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#5 Charles.C

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Posted 28 July 2017 - 10:02 AM

Hi cuong0000,

 

IMO the answer depends on -

 

(1) Are the 2 MDs equally sensitive in the same location? (note - this relates to interpretation of data in Post 3)

(2) is the 1st MD immediately prior the packaging step ? (ie there is no significant additional risk of metallic contamination prior to packaging)

(3) does the "packaging" step you refer consist of loose nuts going into (a) a single bag/box or (b) many small  bags of nuts going into  large outer cartons ?

(4) is there any significant risk of metallic contamination in the "packaging" step ?

 

Assuming Y,Y,a/b,N, IMO the 2nd MD is redundant/can be removed so that 1st MD is CCP.

 

If otherwise, pls inform.


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Charles.C


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#6 cuong0000

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Posted 28 July 2017 - 01:23 PM

Hello cuong0000,

 

As per standards, CCP is the "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" - personally I take it to mean like a "kill step" or a last step to control an identified hazard.

 

If the 1st MD will be the CCP, I would think that the scoring for physical hazard at the next step is reduced, which may mean that you wouldn't need to undergo the CCP decision tree anymore. I'm assuming that after the first MD, the product is sealed and there is no longer an entry point for contaminants.

 

I'm not sure why the 2nd MD would be an oPRP if that's the case, unless the carton box is a verified source of metal contaminants (based on historical records)?

Dear Sigrid B.

Thank you for your knowledge. you're right, after nuts go thought 1st MD, we will scale in one bag 50Lbs and sealing, then this bag will go though 2nd MD. because we fear at step. scale and sealing, maybe crossing metal from worker ( food defense), so after sealing we continue with 2nd MD. Thank you so much for your advice.


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#7 cuong0000

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Posted 28 July 2017 - 01:30 PM

Hi cuong0000,

 

IMO the answer depends on -

 

(1) Are the 2 MDs equally sensitive in the same location? (note - this relates to interpretation of data in Post 3)

(2) is the 1st MD immediately prior the packaging step ? (ie there is no significant additional risk of metallic contamination prior to packaging)

(3) does the "packaging" step you refer consist of loose nuts going into (a) a single bag/box or (b) many small  bags of nuts going into  large outer cartons ?

(4) is there any significant risk of metallic contamination in the "packaging" step ?

 

Assuming Y,Y,a/b,N, IMO the 2nd MD is redundant/can be removed so that 1st MD is CCP.

 

If otherwise, pls inform.

Dear Mr. Charles .

Thank you because explain to me very deeply, it's really helpful with me, now I understood the nature of my problem. Thank again because shared your knowledge to everybody.It is very precious.

Best regards.


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#8 YongYM

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Posted 29 July 2017 - 01:39 AM

 

Dear Sigrid B.

Thank you for your knowledge. you're right, after nuts go thought 1st MD, we will scale in one bag 50Lbs and sealing, then this bag will go though 2nd MD. because we fear at step. scale and sealing, maybe crossing metal from worker ( food defense), so after sealing we continue with 2nd MD. Thank you so much for your advice.

Dear cuong0000,

 

Based on your explanation and the CCP Decision tree, I think the second metal detector will be your CCP and the first metal detector is the CP (or OPRP).

 

 

Yong

 

 


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#9 Charles.C

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Posted 29 July 2017 - 09:57 AM

Hi cuong,

 

This thread IMO is a good illustration that a hazard analysis is always specific to the related process.

 

My query (1) was unanswered so difficult to give a definitively complete answer.

 

Regardless I assume the 2 MDs are of unequal sensitivity in the context of query (1), and as per data in post 3

 

IMO it then follows that the 2 MDs should be inverted.

 

The 2nd MD will now be the CCP and the risk assessment should make the first MD/stage non-significant in the hazard analysis. (This situation is similar to some other processes where a magnet is used to do an initial early "screen" with a MD at the end).

 

@Yong - afaik fssc22000 doesn't use CPs although i daresay SQF would go with yr suggestion. And maybe some oprp experts also.


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Charles.C


#10 cuong0000

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Posted 29 July 2017 - 03:31 PM

Hi cuong,

 

This thread IMO is a good illustration that a hazard analysis is always specific to the related process.

 

My query (1) was unanswered so difficult to give a definitively complete answer.

 

Regardless I assume the 2 MDs are of unequal sensitivity in the context of query (1), and as per data in post 3

 

IMO it then follows that the 2 MDs should be inverted.

 

The 2nd MD will now be the CCP and the risk assessment should make the first MD/stage non-significant in the hazard analysis. (This situation is similar to some other processes where a magnet is used to do an initial early "screen" with a MD at the end).

 

@Yong - afaik fssc22000 does not employ CPs.

Dear Mr. Charles. 

In my case, 2nd MD( Fe2.5, Non-Fe3.5,Sus 4.0mm) less efficient than 1st MD ( Fe1.5, Non-Fe 1.5,SuS 2.5mm). So our Q.A manager decided MD 1 is CCP ( reduce all metal to accepted level), MD 2 is oPRP. Do you think it is suitable ?

waiting for your reply....

Thank you.


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#11 Charles.C

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Posted 30 July 2017 - 01:12 AM

Dear Mr. Charles. 

In my case, 2nd MD( Fe2.5, Non-Fe3.5,Sus 4.0mm) less efficient than 1st MD ( Fe1.5, Non-Fe 1.5,SuS 2.5mm). So our Q.A manager decided MD 1 is CCP ( reduce all metal to accepted level), MD 2 is oPRP. Do you think it is suitable ?

waiting for your reply....

Thank you.

 

Hi cuong,

 

I deduce you are confirming that the answer to my previous query (1) is "No" (and as per my assumption in Post 9)

 

If so, IMO, yr current MD configuration does not make sense.

 

So, as suggested in Post 9, IMO the answer to Post 10 is, effectively, "No".

 

I am vaguely curious as to how yr risk assessment justifies both MD points as being significant risks for the same hazard.


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Charles.C


#12 cuong0000

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Posted 30 July 2017 - 04:12 AM

Hi cuong,

 

I deduce you are confirming that the answer to my previous query (1) is "No" (and as per my assumption in Post 9)

 

If so, IMO, yr current MD configuration does not make sense.

 

So, as suggested in Post 9, IMO the answer to Post 10 is, effectively, "No".

 

I am vaguely curious as to how yr risk assessment justifies both MD points as being significant risks for the same hazard.

Dear Mr. Charles. 

In my case , we can not inverted between 2 MDs as your suggest in post (9), because the height of gate of 1st MD: 20 cm ( suitable with each nut go though), after packing nut in big PE ( 50LBs), ( big bag have the height 37 cm), and 2nd MD height 40cm. As you know, if MD have higher gate, the sensitivity worse. So in this case, we can adjust with best sensitivity for  2nd MD( Fe2.5, Non-Fe3.5,Sus 4.0mm) and 1st MD ( Fe1.5, Non-Fe 1.5,SuS 2.5mm).

 

But, as you comment, 2nd MD total not mean . Now I am really confused ...

Best regards.


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#13 Charles.C

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Posted 30 July 2017 - 10:55 AM

Hi cuong,

 

The difficulty is that the process keeps changing. :smile:


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Charles.C


#14 Charles.C

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Posted 31 July 2017 - 04:16 AM

addendum

 

IMO the answer will eventually come back to the overall risk assessment as used for the hazard analysis.

 

IMO yr first MD could be considered as currently screening the nuts (at a certain MD sensitivity level).

 

You then have a further, final stage where you have to assess the total risk of metallic contamination.

 

If screening is considered Ok as per yr target requirements the net risk will presumably depend on final stage only.

If the risk at the final stage is (a) considered significant, this stage will IMO then be the CCP. If not, then (b) the screening stage MD will IMO be the CCP.

 

If (a) the critical limits may then be considered the detection sensitivity of the 2nd MD, similarly if (b) >>> the det.sens. of the 1st MD.

 

To be satisfactory, the respective sensitivities will both need to meet any regulatory/customer requirements.

 

(Of course, if you go for (b) an auditor may ask you why you insert the 2nd MD. = Just for QA purposes perhaps ? :smile: )

 

This is a rather non-simple hazard analysis IMO, other people may have different opinions. For example i have seen textbook cases where a preliminary magnetic screen was also selected as a  CCP in addition to the final MD/CCP with the justification that the 1st screen acts as an important ("critical")  assist  to the final MD. So you then get either 2 CCPs or a "combined" one. It's justifiable within haccp.

 

PS - with respect to oprp's the decision should logically depend on yr risk assessment/hazard analysis/interpretation of iso22000 clause 7.4.4 (a-g)/iso22004. There are many, many, equally auditorially acceptable, viewpoints over selecting oprps. Based on threads on this forum, the auditor typically wants to see a logical selection procedure for ccp/oprp, not so much details about the choice of the method. And how you validate/implement it.

 

Hope the above is intelligible.


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Kind Regards,

 

Charles.C


#15 cuong0000

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Posted 31 July 2017 - 02:17 PM

addendum

 

IMO the answer will eventually come back to the overall risk assessment as used for the hazard analysis.

 

IMO yr first MD could be considered as currently screening the nuts (at a certain MD sensitivity level).

 

You then have a further, final stage where you have to assess the total risk of metallic contamination.

 

If screening is considered Ok as per yr target requirements the net risk will presumably depend on final stage only.

If the risk at the final stage is (a) considered significant, this stage will IMO then be the CCP. If not, then (b) the screening stage MD will IMO be the CCP.

 

If (a) the critical limits may then be considered the detection sensitivity of the 2nd MD, similarly if (b) >>> the det.sens. of the 1st MD.

 

To be satisfactory, the respective sensitivities will both need to meet any regulatory/customer requirements.

 

(Of course, if you go for (b) an auditor may ask you why you insert the 2nd MD. = Just for QA purposes perhaps ? :smile: )

 

This is a rather non-simple hazard analysis IMO, other people may have different opinions. For example i have seen textbook cases where a preliminary magnetic screen was also selected as a  CCP in addition to the final MD/CCP with the justification that the 1st screen acts as an important ("critical")  assist  to the final MD. So you then get either 2 CCPs or a "combined" one. It's justifiable within haccp.

 

PS - with respect to oprp's the decision should logically depend on yr risk assessment/hazard analysis/interpretation of iso22000 clause 7.4.4 (a-g)/iso22004. There are many, many, equally auditorially acceptable, viewpoints over selecting oprps. Based on threads on this forum, the auditor typically wants to see a logical selection procedure for ccp/oprp, not so much details about the choice of the method. And how you validate/implement it.

 

Hope the above is intelligible.

Dear Mr. Charles

I feel this answer very amazing, after all your explanation, I think I will have risk assessment to justify our decision. 

I am really thank you because you are patience follow my problem and give me your advice very helpful and help me make all clearly. You make me feel love this forum more.

Thank you so much, Mr. Charles.


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#16 Charles.C

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Posted 31 July 2017 - 10:25 PM

Dear Mr. Charles

I feel this answer very amazing, after all your explanation, I think I will have risk assessment to justify our decision. 

I am really thank you because you are patience follow my problem and give me your advice very helpful and help me make all clearly. You make me feel love this forum more.

Thank you so much, Mr. Charles.

 

Hi cuong,

 

You're welcome. I hope the final haccp plan goes well.


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Kind Regards,

 

Charles.C






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