199 replies to this topic

[just me]

Dear Charles,

Sorry for posting my opinion so late in the discussion, I am usually working on the mode of a turtle.

Generally, most companies in the food industries today have Metal Detectors in their process lines designed for the purpose of detecting metal hazards. Often this step of the process is considered significantly risky to be classified as a CCP (Critical Control Point) - most food auditors insist it is anyway.

From where I come from, we always say "Never argue with an auditor". Not a good practice, but no choice.

I would not agree that Metal Detecting to be validation, if it is not a CCP, it may well be verification, to verify that the grinding process is well controlled, not introducing any metal fragments.

IMO. I would consider metal detecting to be a CCP, irregardless whether it is a process step. Say we ommit Metal Detecting as a process step from the flow diagram. The hazard of metal fragment would generally come from the process step of grinding, whereby, when we look into the Codex decision tree, answer for Q2 would be No, Q3 might be Yes, while Q4 would be No, rendering the process step of "Grinding" as a CCP. How would one monitor that? By using a metal detector. So, at the end, even if "Grinding" is a CCP, monitoring would still round back to metal detecting.

Indeed a metal detector is a CCP regardless. Interestingly, in a cocoa powder manufacturing facility where metal detectors are all over the entire piping line, where should the CCP be?

IMO, I'd say the last point, be it before bagging or before bulk loading. Same concept as the many filters in an oilmill.

Say, would there be so many metal detectors in the cocoa powder plant, or is it just magnets?? Controlling magnets and controlling metal detector are very different.
Metal detectors are usually simpler to control, IMO, because most metal detectors work in a way that it detects every single product and reject those with metal detected in the product, so the affected products would be quarantined.
Whereas for magnets, when we actually catch something on the magnet, it may not mean that all metals were caught. We may have to think not just about the gauss, but also the flow-rate of the product as a CL.

I know - it sounds pretty but lets be realistic. We have all the OPRPs in place and we still have to "create" a CCP for a monitoring step to a CCP.

To me, O' PRP and CCPs are similar. We choose to "elevate" certain O' PRP to be CCP to further emphasize on the control point, because it has a direct impact on the safety of the product. In time, the CCP if well controlled might even be classified to be an O' PRP again, because the likelihood of the hazard would change from high to low.
I have seen an instant noodle processing plant having frying as a CCP initially, and the frying temperature as monitoring. But after a few years, they noted that the fluctuation in the frying temperture was minimal, but the process step which was creating the problem of "under frying" was actually the weighing and the cutting of the noodle strands - too high volume in a contrained space affects the frying process, so "weighing" became the new CCP.

Got another one for ALL to think about - A fish canning facility with a vacuum seamers when seaming is considered a CCP step (torque on seaming integrity etc).........then immediately after seaming, we have the seaming detector (again this is usually treated as a CCP when ALL that it does is only a validation step to the identified CCP.

Surely we cannot have two CCPs when one is good enough. If we look at the usual flow of determination under the Decision Tree...........it strictly mentions "process step" and NOT Monitoring step.

Never seen a seaming detector, not sure how it works, but in canning, what some people do is just to cut open the seam and check on the over-lap, maybe it is the "old" conventional way, but still works. I'd reckon the seaming detector functions on the same concept.
I agree that it shoud be either the torque or the seaming detecting to be a CCP. However, I do believe, that the seaming detector is again, verification, to verify that seaming is carried out properly.
Validation would be carried out initially on the CL of the torque: is that particular value sufficient to ensure proper seaming?

IMO, validation is not something that is carried out on routine basis (as in seaming detecting or metal detecting), it is usually carried when we first design ordevelop the system, or when we modify the system.

Kindly let me know if my concept is wrong. I'm some what lacking in a mentor.


Cheers,

[Charles Chew]

From where I come from, we always say "Never argue with an auditor". Not a good practice, but no choice.

Not true - a good auditor must be a good listener in order to engage in a "two-way" meaningful external communication afterall, the auditor is one of the approved providers of services and if I have a say in it, would likely to be removed from the next audit.

So, at the end, even if "Grinding" is a CCP, monitoring would still round back to metal detecting.

Actually, IMO this is the only answer that has satisfied me AND of course, metal detecting is A CCP......in whatever argument you wish to take it but I think Wai Ling had explained extremely well

Say, would there be so many metal detectors in the cocoa powder plant, or is it just magnets

You picked it up! The moment gauss strength was mentioned, it had to be magnets. The mistake was mine but you are absolutely right about the flow rate which when identifying the gauss, you would have determined the correct magent type anyway.

under frying" was actually the weighing and the cutting of the noodle strands - too high volume in a contrained space affects the frying process, so "weighing" became the new CCP.

Consistency in process control to deliver the intended food safety level for every production batch is what we are talking about. ....and at the end of the day, temperature / time is the CCP. While, a CCP is modeled against the outcome of a HACCP Analysis, the OPRP may be derived from the HACCP Plan to monitor a QCP process but essentially OPRP and PRP are prerequisite programs.....so they are really very different..........check process objectives versus product objectives

Cheers

[just me]

Not true - a good auditor must be a good listener in order to engage in a "two-way" meaningful external communication afterall.

I agree, don't we preach that everytime during trainings on audits? Most of the more competent auditees will try to justify. But for some, they would most probably just nod and agrees on everything the auditors "dictates".

Consistency in process control to deliver the intended food safety level for every production batch is what we are talking about. ....and at the end of the day, temperature / time is the CCP. While, a CCP is modeled against the outcome of a HACCP Analysis, the OPRP may be derived from the HACCP Plan to monitor a QCP process but essentially OPRP and PRP are prerequisite programs.....so they are really very different..........

Say, all those magnets on the processing line, which we say would be O' PRP (except for the last points), would they be QCP, or FSCP???

check process objectives versus product objectives

Not in my vocabulary, will check it out. Thanks.

Cheers,

[It's That Man Again]

Dear Charles,

As an auditor myself I have a view to offer. The Metal detector is both a process step AND a preventive measure; it is a CCP, for the simple reason that it may fail to detect or reject a contaminated item. The monitoring and limits then come down to the risk assessment of likely contaminants, relevant sensitivity and regular test piece use and calibration.

I look forward to being a regular contributor to the forum - a much needed tool for all of us!

[quote name='charleschew' date='Mar 17 2004, 07:01 PM' post='1168']
METAL DETECTOR: A Monitoring Activity or a CCP?

[Simon]

Welcome to the forums ITMA.

Regards,
Simon

[Charles Chew]

The Metal detector is both a process step AND a preventive measure; it is a CCP, for the simple reason that it may fail to detect or reject a contaminated item.

Dear ITMA,

Yes - its all in the application of the Codex CCP Determination Tree. If we run through the questions, we will have the same common determination result regardless of whether the product characteristics are likely to be altered or not.

As part of the system's overall process performance, it is certainly a significant procedure to "prevent, remove or reduce" to your defined acceptable level and undoubtedly, as one of the important combined control measures.

Thanks. Other interesting views are welcomed.

[Charles Chew]

Dear all,

We have discussed this issue of metal detection at a fairly good length now and judging from the number of hits on this subject, there is indeed a great deal of interest.

I just like to share my final point of view on metal detection.

Just a few days ago, I have the experience of having a BRC Auditor that came out of UK to perform a second party audit at one of our facilities and the first thing he mentioned was whether we have a metal detector. Is it absolute to have one?

I told him that our ISO 22000 is also a due diligent FSMS system as much as BRC and that appropriate risk management has been taken to ensure that the risk of metal contaminant is unlikely to occur (zero tolerance does not mean that it would not occur)

After evidence of risk management and risk assessment were presented, I was happy that he had the sense to accept our explanations.

However, back to the current subject forum........a metal detector is definitely to my mind not necessary always a CCP (in fact often it is not) but the result of your CCP determination would be relative to your prevailing FSMS boundary and Pre-Process and In-Process Control Management.

There may be a point in time where metal detection is only a validation process which is no diffrence from performing microbiological testings.

Do you think that I should seriously consider setting up a "Metal Detection Sampling Plan" which could well mean that if n=5 and c=1 and when the metal detection indicates that I have 2 failed samples, the entire production batch should be contained for investigations or disposal

It is obvious there is clearly so much similarity between metal detection and micro test but why do we generally not consider "Micro Testing" as a CCP Process Point while we insist that "Metal Detection" is.

I am very sure that we would have a real life test case in the court of law one day on the tolerance criteria for metal detection as a critical control point or should it be re-classified to reflect what it really should be.

Again, I like to point to the fact that having a solid metal detection system does not mean that you are guaranteed a fail-proof program. WE would be fools to think so.

In reality, taking the cue from the recent chocolate product withdrawal saga, there is nothing to it than having a ROBUST Food Safety System in place. This is also where ISO 22000 is so effective with its strong focus on systems validation and verification for continual improvements.

[Charles.C]

Dear CharlesChew,

I'll chew the bone a bit more.
As an unofficial audit of auditors it would be interesting to know if anybody has ever had an auditor object to the inclusion of a metal detector as CCP (or even multiple CCPs come to that). If so the associated process would be of interest.
Sometimes guaranteeing 'peace of mind' by excess monitoring is a worthy objective ?

Rgds / Charles.C

[GMO]

You have to face it that if metal was found in your food and you didn't have a metal detector in your factory; you will be liable and will be successfully prosecuted.

If you remember, if something is not a CCP; this means it is possible for the line to run without it. Would you run without the metal detector?

I take your point that it's too late in the process but also metal contaminants are often single screws, nails etc so by having one find it doesn't necessarily follow that there was more (and good practice dictates you always follow up and find the source anyway to make sure).

As I've said before, most enforcement bodies are pragmatic; they realise that a piece of bone is not necessarily going to be easy to detect and remove; however, metal is easy to detect and remove. To an extent you expect intrinsic foreign bodies to occasionally be in food and be able to make it through your prerequisites, that's why on fish products there would always be a "may contain bones" warning or "may contain stones" on stoned cherries but "may contain metal" is never going to be acceptable.

We all have prerequisite programmes in place, e.g. preventative maintenance but I'm sure all of us have had an occasion when they have failed. (You must also consider the possibility of deliberate contamination by your staff.)

[GMO]

Oh and micro testing is normally not a CCP because contamination is not usually uniform so false negatives can be found and by nature it is a sampling exercise whereas metal detection tests all products. Also micro tests take too long. Imagine waiting for Listeria results on a sandwich with a 2 day life!

I think if you can, it's simple, it's effective and if you ran without it and had a single contamination you could seriously injure someone so why argue about it? It seems easier and more common practice to control it as a CCP!

[Cathy]

Just another opinion on metal detectors. I don't think it is possible or correct to ask if they are CCPs in general. Every process must consider if the hazard is likely or if the metal detector is just a customer requirement of some sort. HACCP just can't be one size fits all.

Secondly, I really enjoyed the attention to detail in asking if it is truly a control point. If the detector only identifies metal - it is not the control point. Control is where you can reduce the hazard by removing it and doing something about it. The rejection mechanism is the control. Often it's all part of the same equipment and so the whole thing is named a CCP....the point where the mechanism is there to identify the hazard and exert control. I have seen cases where the metal detector rejection system is not working properly and only a light or other indicator is available to show when metal is present. At this point - I suppose a human being is the control.

Just my two cents....or Euros - or whatever you think it's worth.

[GMO]

In every HACCP I've ever written it's the detection and rejection which is the control and this is tested along with the failsafe mechanisms. If a metal detector just alerts a member of staff; I agree, it's a waste of time.

[walabies]

I voted it as critical control point. The metal detector functions as detecting the metal content in the product. Without it, the metal hazard remains, and once detection, rejection is done and thus valids as a CCP. Monitoring to me is to observe the changes within the product, and once you monitor, you don't do anything to the hazard.

Edited by walabies, 19 June 2008 - 05:14 AM.

[Erasmo]

METAL DETECTOR: A Monitoring Activity or a CCP?
Generally, most companies in the food industries today have Metal Detectors in their process lines designed for the purpose of detecting metal hazards. Often this step of the process is considered significantly risky to be classified as a CCP (Critical Control Point) - most food auditors insist it is anyway.

What is the general consensus? A "Critical Monitoring Step / Quality Control Point"" or a "Critical Control Point" ?

Cheers

Charles Chew

Hi Charles,
by definition ALL CCP's has to be monitored. So, both answers are valid.

[Cathy]

Hopefully this is better late than never. I had been hunting for a document about foreign objects - finally found it. In an FDA document of 1999 (yes, a bit old!). It discussed the 7-25mm understanding. Regulatory action is not advised unless a foreign object is hard or sharp and between 7 and 25mm in size. However - what we often ignore is that it continues with more information... If a hard or sharp foreign object is less than 7mm AND the intended use includes special risk groups such as children or elderly is is considered a hazard. We should not generalize the 7-25 mm size as a rule for all products.

[Erasmo]

Hi Charles

Are they detectors? Or magnets? Is a separate rejection system included?
My opinion...


CCP - Detector
Critical Limit - >0 count. Detector sensitivity 0.5mm Fe/non-Fe/St-St
Monitoring Procedure - Audible & visual alarm at detection
Records - Detection count record. Functionality check record
Verification Procedure & Frequency - Detector functionality check every hour
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action.

Hi Edwina,
Mi Opinion:
CCP - Detector
Critical Limit - >0 count. Detector sensitivity 0.5mm Fe/non-Fe/St-St (That is "acceptable level")
Monitoring Procedure - Audible & visual alarm at detection (see below)
Records - Detection count record. Functionality check record - agree.
Verification Procedure & Frequency - Detector functionality check every hour (that is monitoring. - see definition 3.12 ISO-22000)
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action. (This a "correction" see definition 3.13 & 3.14).

Every CCP has to be monitored so, both answers are correct (principle 4)

[wamamili]

do we have a situation whereby a series of steps make a ccp. Then in such a situation ,critical limits should be result of the hazard presence after going through these steps. i hope you meant this Charles.

[Charles Chew]

Hi Wama
I have restrained from participating in the forum due to certain professional reasons which Simon is fully aware of. However, as this subject was initiated by me, its only fair that I pen my opinion.

do we have a situation whereby a series of steps make a ccp. Then in such a situation ,critical limits should be result of the hazard presence after going through these steps

There can be a series of control measures along the process environment that are designed to monitor an identified hazard or a series of control measures acting simultaneously and in concert to specifically monitor an identified hazard. Whether this individual step or these integrated steps become part of your HACCP Plan or the Food Safety Control System, you have to make that risk management decision under the prevailing circumstance.

However, if there is a CCP step to control / monitor an identified hazard (such as a wire mesh shifter to trap ferrous and other non-ferrous impediments ahead of a metal detector - MT) then it is up to you to decide whether the MT is a CCP or just an OPRP.

Whichever way you wish to take it, they are both correct but as an auditor, I would also accept, provided objective evidences are available that the MT is as a continuous validation to confirm that the shifter (CCP) remains effective and efficient as intended.

Or you may place the MT under your OPRP Plan with the level of stringency equivalent to the design of a CCP but remains only an OPRP.

In my opinion, an FSCS is always dynamic in nature, therefore, there is no right or wrong answer or approach but rather objective evidences must prevail at all circumstance.

[RachelCD]

Metal detectors have always been a thorn in my side when developing HACCP plans, because I've never been confident in their sensitivity. There are so many variables that influence the performance of the MD -size, density and conductivity of the product, shape and orientation of any metal contaminant, environmental conditions, etc. Based on my experiences, I honestly don't believe they reduce hazards to an acceptable level. Trying to successfully detect fragments of 304 stainless in 10Kg blocks of hard cheese during validation was not always successful. It works ok for the test pieces, but when simulating the kind of non-uniform fragment you might find in a product (drill swarf or sheared pieces of metal) there was not 100% detection.
I also think they give manufacturers a false sense of security - "hey, we lost a bolt! Oh well, the metal detector will pick it up". At the end of the day, we are stuck with them and just have to make the best of it - they are still better than nothing. For most manufacturers, alternatives are too expensive and x-ray machines have their own issues. Technically it's hard to avoid treating them as a CCP if you have them in place, but I just don't think they are reliable enough to be effective.
My 2 cents, anyway

[Charles Chew]

There are so many variables that influence the performance of the MD -size, density and conductivity of the product, shape and orientation of any metal contaminant, environmental conditions, etc.

Uncertainty in detection - how does a food auditor view this comment and what sort of impact does it have to an audit conclusion / report. (Personally, I have observed numerous failures in metal detecting steps carried out in very hgh profile organizations. Its frightening but yet appears to give a false sense of confidence amongst food processors)

[Salamony]

we have to clarify if the position of metal detector on the line and the combination with other control measures. that's means:
1- does the metal detector is the last defense line on the production line? if there's 2 defense lines we cannot consider both as a CCP, 1st may be OPRP and other willbe CCP.
2- we cannot consider all control measures are CCPs
3- we can use Foreign bodies prevention checklist
4- we have to consider the frequency of likelihood of occurrence against the severity of hazard to maintain the true risk.
5- Many CCPs refelct a weak HACCP Plan

[nicolejee]

Hi all,

I need some help from you guys

I have just joined a food company that has a new factory built for their cheese and antipasto products. The building is brand new and the process is mainly just cutting and packing for cheese + marinating and packing tomatoes. As per standard GMP and SOP, we get products from approved suppliers and no loose items in factory and all our machinery is intact as they are pretty new. In this case is it necessary to have metal detection set as a CCP? How should i justify that metal is a risk to the product when our machineries generally will not pose a physical hazard to the finish goods?

Nicole

[Charles.C]

Dear Nicole,

These comments may already exist on this huge thread in which case my apologies for the duplicate. Might hv been better to start a new topic.

You need to validate yr opinion regarding the negligible risk of metal contamination from machinery, etc. This is (correctly) the auditing expectation. Since new, I presume no direct data available (?). One alternative way would be to find an equivalent published model HACCP plan or similar analysis of yr system.
Some machines IMEX (not cheese area) are typically assumed to be suspect, others not.

Eg have a look at this link which is rather more general than it looks –

http://seafoodhaccp....le_pdf/Ch20.pdf

Rgds / Charles.C

BTW, Welcome to the forum !

[Rey]

Hello All,

As a Food Safety Coordinator and with my experience dealing with USDA/FSIS Inspectors, metal detection is typically a monitoring point and not a CCP. In our HACCP plan (or our entire plant) we have 6 metal detector stations which include raw materials to finished product.

As long as the metal detection stations are monioted throughout the hours of operation and can be proven to functioning properly, it is considered a monitoring point and not a CCP.

Thanks,

Rey

[Steve E]

Hello All,

As a Food Safety Coordinator and with my experience dealing with USDA/FSIS Inspectors, metal detection is typically a monitoring point and not a CCP. In our HACCP plan (or our entire plant) we have 6 metal detector stations which include raw materials to finished product.

As long as the metal detection stations are monioted throughout the hours of operation and can be proven to functioning properly, it is considered a monitoring point and not a CCP.

Thanks,

Rey

A bit of new member solidarity - I agree with you Rey

Although I have to ask does it really matter?

Metal detection can only be described as a monitoring activity if you wanted to make it a CCP the step should be titled "Passing food through metal detector" (to be pedantic)

I must own up to not reading the whole thread but agree with those who state most auditors inspectors demand it is a CCP so I agree to keep them happy.

S