199 replies to this topic

[yorkshire]

Doug,

I think it is normal for a process to produce small particles of metal.

What you are doing in the HACCP is deciding on what size metal could cause harm to the consumer. This one is always difficult one to decide, e.g. If you pack a small bag and your detector sensitivity is 1mm Ferrous then you are accepting that any ferrous metal smaller than a 1mm sphere equivalent is acceptable to pass through the process; then you pack the same product in metalised film and say your sensitivity is reduced to 2mm - this means you now accept something twice the size! You either then change the process, like putting in x-ray, throat detector, etc. or you accept the sensitivity of the machine.

What I believe is important is finding things out of the norm or that have passed through your process undetected (customer complaints).

Firstly look at your customer complaints. Do you receive any? What size are they? Have they harmed anyone? What type of metal are they? Will installing a detector prevent these complaints?

The next thing to do is closely monitor the process. You say that your magnets pick up some metal, do you know how much it usually picks up? Would you be able to put in a procedure that would identify when there was a problem? With metal detectors the important thing is to investigate the source of each piece of metal detected as soon as you can. It is useful to put an alarm on metal detectors so that the operator is alerted as soon as something is detected. You may put in you procedure that if the operator hears more than 2 rejections during a shift then this is highlighted and an investigation / decision is taken.

Sorry I seem to be rambling a bit.
Is this of any help?

[Doug W]

You say that your magnets pick up some metal, do you know how much it usually picks up? Would you be able to put in a procedure that would identify when there was a problem?

We pick up more material than I am comfortable with on the first magnet. The second magnet normally just picks up tiny sand grain size particles.

There is a problem whenever we run the dryer. We thought that we had fixed it by grinding the entire inside of the dryer but now we think that the problem is in a different, harder to get at, expensive to open, too tiring to think about area.

But I guess we will have to open the nasty part of the dryer and give it a going over.

Thanks,
Doug

[Simon]

I know nothing about metal detectors, but doesn't this show the value of them for risk identification and minimisation.

Regards,
Simon

[okido]

Firstly look at your customer complaints. Do you receive any? What size are they? Have they harmed anyone? What type of metal are they?
Will installing a detector prevent these complaints?

I do believe that it is a bad idea to wait for customer complaints.
Not all customers complain and if they complain you are always too late with adequate measures.
I have no experience with magnets or metal in products but from the story I have seen till now I would take apart the dryer and improve it so that it does not loose any unacceptable metal particles.
What is acceptable needs to be decided by you.

Okido

Remember to share good fortune with your friends!

[yorkshire]

I do believe that it is a bad idea to wait for customer complaints.

I'm not suggesting waiting for customer complaints but when you are installing further controls you need to determine whether these are going to have any effect. These products have been sold in the past so is there a history of any metal getting through?

I have no experience with magnets or metal in products but from the story I have seen till now I would take apart the dryer and improve it so that it does not loose any unacceptable metal particles.

Prevention is better than cure

[Doug W]

I'm not suggesting waiting for customer complaints but when you are installing further controls you need to determine whether these are going to have any effect.

In our case, there is no history of complaints from customers about metal in the product, I would like to take care of things before that happens.

[SAM]

Our recent BRC - Food auditor seemed surprised that we had a metal detector on our production line. We produce bottled vinegars down a stainless steel line. It did seem a little odd to think that we don't need them, particularly when they insist we use blue metal detectable plasters!

[yorkshire]

It did seem a little odd to think that we don't need them, particularly when they insist we use blue metal detectable plasters!

This is a good point.

By the way here are 2 links to recent recalls regarding metal:

Waitrose

Nestle

[frawat]

Hi Fiona, greetings from Perú.

I hope you can comment (sorry to be late, it is the first time I participate in the forum).

I work in the frozen vegetables industry. We have a metal detector with a reject valve (gravity) and another one conveyor type (just and alarm and the conveyor stops). We have had different approaches in the past but now we work as follows:

The metal detector is a CCP but we think there is also an operational PRP at the same process step.

CCP --> monitors the detection and reject mechanism every hour; corrective action is the same as you mention + stop using the detector until it can be adequately validated again.

Operational PRP --> to pass every box (usually 10 kg boxes) or feed the gravity conveyor and be alert to the signal/alarm, check the product, find the metal, etc., etc.

I think I understand that for you this "operation" is equivalent to the monitoring of the CCP. Also your verifying procedure would be equivalent to our monitoring. CL is detector sensitivity, and this we check every hour.

In practical terms it is the same although we think that CCPs should not be related to "operations" or monitoring human beings (to be alert, or to follow a procedure, avoiding the possibility that a box goes directly to the cold store, etc.). This would be a PRP because it depends on putting the right person in the job, training, etc. Sorry if I misunderstood you, I am not suggesting our approach is right and yours wrong.

I look forward to your comments.
Many thanks and regards,
Francis

Hi Charles

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

CCP - Magnet
Critical Limit - >0.5g catch per day
Monitoring Procedure - Collect and weigh magnet catch
Records - Weight trend analysis / charting
Verification Procedure & Frequency - Test strength of magnet (??) Monthly
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action.

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.

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

[APPAJI]

Emergency handbook for food managers could be an example ?

Helloo All
I am new here and have spent whole night todaygoing through all the topics. I wanted to contribute on few ponits but I think my registration was not through before this . A good Question on Mettal detection I agree on the point that Metal detector is only a detecting action and agree that it is not transforming the product status but subsiquntly the action of removing the detected material with metal pieces from production is the step of CCP . As per Charles Question if we go by Codex Desition tree Q4 will help us to understand that Next step if present for elimination yhen the subsiquent step is a CCP- in this way the last Metal Detector will be our CCP

[bibi]

hi

new brc guideline concerning the metal detector the strips Fe/nonFe/St-St should have a certificat of conformance.

bibi

[Charles.C]

Regarding discussion this thread concerning what represents a safe size of metal particle.
As a substantial consumer of one of the products referred in a recent alert links in this thread (small metal particles, hmm) I felt motivated to comment.
Is there any validification data supporting that the average current metal detector limits ( ca.2mm?) have effectively controlled the safety aspect of such items? eg any published data on occurrence / frequency of ('serious') health related issues vs size.
As an example consider this link which I personally found a bit startling -
http://www-seafood.u...pt28.htm#Glass2

Compare to the response -
http://www.fda.gov/b...6/NEW01323.html

Rgds Charles.C

[Simon]

Regarding discussion this thread concerning what represents a safe size of metal particle.
As a substantial consumer of one of the products referred in a recent alert links in this thread (small metal particles, hmm) I felt motivated to comment.
Is there any validification data supporting that the average current metal detector limits ( ca.2mm?) have effectively controlled the safety aspect of such items? eg any published data on occurrence / frequency of ("serious") health related issues vs size.
As an example consider this link which I personally found a bit startling -
http://www-seafood.u...pt28.htm#Glass2

Compare to the response -
http://www.fda.gov/b...6/NEW01323.html

Rgds Charles.C

Yes the metal particles (2.7mm) found in the baby milk formula are outside the FDA regulation of 7 - 25mm - so strictly/legally they are OK. I suppose because it's an infant product Mead Johnson are being extra cautious, but is it overkill if there is no risk as per the FDA regulations?

[PrincessPP]

Halo Ms Fiona,

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.

what does the > 0 count means?
thanksss a lot

[sorry, im a beginer in HACCP planning]

[Simon]

Halo Ms Fiona,

what does the > 0 count means?
thanksss a lot

[sorry, im a beginer in HACCP planning]

Hello PrincessPP,

It's a mathematical sign:
> means greater than
< means less than

and you know what = means

Is that OK for you?

Simon

[PrincessPP]

Hello PrincessPP,

It's a mathematical sign:
> means greater than
< means less than

and you know what = means

Is that OK for you?

Simon

Mr. simon

thanks 4 spending time answered me
so, thats mean > 0 count is more than 0 metal object detected?
and also means that can't have even 1 count on metal detection?

[actually, im doing my assignment on HACCP]

thanksss agn Mr. simon


PrincessPP

[Simon]

Mr. simon

thanks 4 spending time answered me
so, thats mean > 0 count is more than 0 metal object detected?
and also means that can't have even 1 count on metal detection?

[actually, im doing my assignment on HACCP]

thanksss agn Mr. simon


PrincessPP

No problem Princess. You have understood correctly; feel free to ask if you need further help with your assignment.

By the way you can just call me Simon.

[Charles Chew]

I know and eveybody knows that a "metal detector" is a CCP but are we correct in our determination.

As I had argued earlier that "metal detection" is NOT part of a "Product Conversion Step" but rather a monitoring check and it DOES NOT alter the fundamental of the product during the conversion process - WHY should it be a CCP?

Unlike a "Control Measure" for a pre-determined CCP such as a "Cooking Process Step" where cooking Time and Temperature plays an important role - it does participate in the process by detroying pathogens.

Don't you think its more appropriate to consider control under a "Service and Maintenance Program" as an OPRP rather than a CCP Any thoughts on this one!

[Charles Chew]

Take another viewpoint

Since a Metal Detector is treated as a CCP because it functions as a method / tool that detects ferrous contaminants then.........

What about the method for culturing micro-organisms. If our culturing method is wrong, then we would not be able to obtain accurate determinations. We would therefore consider using the correct culturing method as an extremely important tool that detects the level of bacteria load. Therefore, the Culturing Method is a CCP and should be validated before use.

I know its silly but what do you think! OPRP or CCP

[bibi]

Take another viewpoint

Since a Metal Detector is treated as a CCP because it functions as a method / tool that detects ferrous contaminants then.........

What about the method for culturing micro-organisms. If our culturing method is wrong, then we would not be able to obtain accurate determinations. We would therefore consider using the correct culturing method as an extremely important tool that detects the level of bacteria load. Therefore, the Culturing Method is a CCP and should be validated before use.

I know its silly but what do you think! OPRP or CCP

oh oh Charles

not again, it's a tricky one now.
anyone in the forum working for OXOID may be can give us their taughts.
you make me uncomfortable, OPRP or CCP?
bibi

[Charles Chew]

not again, it's a tricky one now

Hi Bibi,

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.

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.

Bibi, please accept my apologies if I had confused you but I am sure all these will come down to a common view eventually.

[Charles.C]

I know I'm sticking my neck out but here goes -
In a Canadian ref. I posted elsewhere,
http://www.inspectio...ol2/vol2e.shtml

I can see a comment regarding the dtree Qu.3 ( Is this process step specifically designed to eliminate or reduce the likely occurrence of this identified hazard to an acceptable level?) -
<<"Specifically Designed" is any procedure or step in a food process that is designed to specifically address the identified hazard. Examples of this are: the retorting operation in a canning plant, a pasteurization step, the chlorination of cooling water, the addition of a metal detector to a process line, a particular sanitation procedure performed by the operator to clean contact surfaces without which the product would be contaminated. >>
This appears a rather flexible interpretation to me (??) but perhaps it answers yr question as 'maybe'. Now you/someone will probably present a counter-example to unvalidate. No problem.
Rgds / Charles.C

added, sorry, the link has changed (!!)
try
http://www.inspectio...vol2/4-7e.shtml

Edited by Charles.C, 13 April 2006 - 05:53 AM.

[Charles Chew]

But Charles, everything that was mentioned on that list of examples is a process step except for metal detector which is a plain validation step......did you realise that.

And, what about the CL monitoring on the sieve mesh / cloth which is for the control of the specific CCP.

Metal detector has always been taken for granted to be a CCP. Should we just treat it as such because its the norm. I am just trying to point out that it need not be a CCP if it was there to serve as an "insurance" i.e. validation step.

Since EU is now looking into setting Micro Criteria for specific food type, the test method when determined shall have to be a CCP because if another method is used - its a violation but it is only a confirmation step not a process step.

My reason of argument here is about process step versus in-process validation. Perhaps, other members would like to throw in their comments but one thing is for sure, neither Charles C. or myself is right or for that matter wrong.

Its only another viewpoint of determining a CCP

[Charles.C]

I agree, it's all about the meaning / use of CCP.
I also agree that you can classify all the activities in my ref. as 'processes', eg concerned with product conversion, monitoring, sanitation. I suppose you can also classify them as 'steps' if this is considered useful.
Is there any requirement which limits the range of process types which may be considered in the evaluation procedure for a CCP?
I believe the HACCP concept is requiring us to take as wide a view as we think necessary in order to assess the (safety) risks related to the particular item concerned and thereby eliminate/minimise these risks where they are considered to have an unacceptable probability of occurrence/severity. A decision tree is one tool (user-friendly) for making this assessment, other (CODEX) acceptable procedures exist also (but maybe not to ISO 22000, sorry I haven't read it yet).
So, if you have a step/process whatever in yr system which you consider does not comply yr risk assessment requirements for a (validated) CCP, it over-rides all the GMP / PRP etc side-issues IMO (and vice-versa). I think this aspect has been exampled early in this thread and also in the one regarding chlorination - http://www.saferpak....st=0
Rgds / Charles.C

[Charles Chew]

I believe the HACCP concept is requiring us to take as wide a view as we think

Hi Charles
I am absolutely on the same page with you on this and thats probably the reason behind the differences in our opinion mind-set. Dynamic thinking has to be the game in ensuring that the combined measures work towards achieving the intended objectives of the .......shall we call it the schematic flow instead.

Cheers
Charles Chew