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Code of Practice for the Prevention and Control of Metal Contamination

Control of metal 1.3.7

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#1 tobert1985

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Posted 19 December 2017 - 03:21 PM

Hi All,

 

Just wondering what all are doing and any examples of best practice for the below clause;

 

 

1.3.7 Repairs that result in metal components being removed should identify the equipment as ‘complete’ in this state e.g. if a screw is removed and a hole is left, it should be recorded and personnel made aware that a missing screw in this position is ‘normal’. This may be demonstrated by marking the blank hole or using a photographic standard. A documented system should be in place to ensure that these are known and accounted for. Checks should be carried out at a frequency determined by risk assessment to ensure the integrity of all equipment remains intact.

 

 

Any guidance would be much appreciated, thank you


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#2 chris@crepecuisine

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Posted 20 December 2017 - 02:16 PM

How much is a replacement screw nowadays?


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#3 TimGoss

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Posted 20 December 2017 - 06:04 PM

Where did this clause come from (SQF, BRC, UK's version of FSMA if there is one)? I've never seen that one before, but I have only dealt with SQF and FSMA. It seems to me like the thought process behind the clause (or is it a rule, best practice?) was so that you could easily identify whether an empty screw hole means "oops, there's a screw in our product" or "that's supposed to be that way". My suggestion would be to create a maintenance policy/procedure that states any empty holes are to be marked by sharpie with whatever designator you and maintenance team decide. It really depends on how dirty or involved your process is though. Depending on where that clause came from, you might also have to institute verification checks that this procedure is being followed as well as something showing you catch any screws in some way (maybe a HACCP metal detector with kickouts), and this is just a way to track down root cause.


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#4 Zerokill_Guiding

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Posted 21 December 2017 - 10:36 AM

Hi All,

 

Just wondering what all are doing and any examples of best practice for the below clause;

 

 

1.3.7 Repairs that result in metal components being removed should identify the equipment as ‘complete’ in this state e.g. if a screw is removed and a hole is left, it should be recorded and personnel made aware that a missing screw in this position is ‘normal’. This may be demonstrated by marking the blank hole or using a photographic standard. A documented system should be in place to ensure that these are known and accounted for. Checks should be carried out at a frequency determined by risk assessment to ensure the integrity of all equipment remains intact.

 

 

Any guidance would be much appreciated, thank you

 

So in our plant we cover any screw or misc maintenance holes with duct tape, write our initials on it and also the date.

We then create a Work Order to address the issue.


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#5 chris@crepecuisine

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Posted 21 December 2017 - 10:39 AM

Can't the hole be filled in with some sort of filler, metal detectable filler of course


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#6 GMO

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Posted 21 December 2017 - 11:53 AM

That's either M&S or JS isn't it?  I recognise the clause and I think both have something similar.

 

If I'm honest, we don't do it well.  It's a bloody nightmare.  Sat in a cosy office in waterside or Holborn, I'm sure this makes perfect sense.  Remove a screw deliberately then you should know it's been deliberately removed so that if it's later found to be missing you know there's not a problem and vice versa, you can recognise "genuinely lost" screws. 

 

Except now we enter the real world.  Do you check every screw on every bit of kit every day?  Nope.  You can't.  Some of them won't be visible for a start. 

 

It's important though to note the wording.  It says "should" not "must" so some careful risk assessment and an alternative control may do you proud.  I think we've put some fudgy words in the post engineering work hygiene clearance about it but if I'm honest, that is all.  Practicality has taken over in my mind on this one and I really should go back and challenge this clause at some point then get the COP writer to come to a site and actually do a check...  After all, a screw is only one thing.  There may also be metal nuts in there but (and probably more dangerous) circlips.  Are you really going to do a pre start check down to circlip level?  Give me a break.  It's not possible!


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#7 chris@crepecuisine

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Posted 21 December 2017 - 11:56 AM

If you metal detect your products then that must cover the hole


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#8 GMO

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Posted 21 December 2017 - 04:14 PM

If you metal detect your products then that must cover the hole

 

Really?  Why?  Some machines come with pre drilled holes for machine adjustment.  Do they need to be filled?  What would you fill the holes with?


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#9 nkwekam

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Posted 21 December 2017 - 05:27 PM

what if you do fine the missing screw?


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#10 chris@crepecuisine

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Posted 22 December 2017 - 07:47 AM

Fill the hole in the process with a metal detector


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#11 Charles.C

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Posted 22 December 2017 - 01:06 PM

Hi tobert,

 

So what is the Food Standard relating to yr OP ?


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Kind Regards,

 

Charles.C


#12 GMO

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Posted 27 December 2017 - 10:25 AM

Fill the hole in the process with a metal detector

 

Oh I see what you mean.  No some retailers demand that "missing items" are also accounted for as well as having a metal detector.


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#13 GMO

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Posted 27 December 2017 - 10:26 AM

Hi tobert,

 

So what is the Food Standard relating to yr OP ?

 

It's Sainsbury's Code of Practice.


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#14 Charles.C

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Posted 27 December 2017 - 12:12 PM

It's Sainsbury's Code of Practice.

 

Thanks GMO. I was beginning to think it was fictional.

 

I wonder if they also demand marking of (original) holes. Not so rare IMEX where a large part was mass produced and then retained through subsequent revisions.

 

Bit like the electricians'  trick of simply cutting/tapeing the ends of old wiring and then leaving it all for posterity. :smile:


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Kind Regards,

 

Charles.C


#15 GMO

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Posted 28 December 2017 - 12:54 PM

 

I wonder if they also demand marking of (original) holes. Not so rare IMEX where a large part was mass produced and then retained through subsequent revisions.

 

 

Strictly speaking, yes they would.  This isn't uncommon as often the same part will be used for different applications but also some holes are pre drilled for adjustment purposes.  It's a sensible clause on paper but in reality completely unworkable.  Marks and Spencer's have an almost identical clause.


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