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New X-ray Machine, Addressing additional CCP... or not?

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#1 MGB503

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Posted 16 May 2018 - 05:27 PM

Hello all...

 

First time poster here and new to the group, been racking my brain since we got this thing on which direction to take it with so i will do my best to explain the situation. i did some researching on the topic throughout the site and came across a few helpful posts but still undecided.

 

We just purchased a new X-ray machine and placed it at the end of our production line, we products jams/jellies/spreads & sauces. its placed after all filling/capping/packaging steps other than being placed into cases, at the time it hits the x-ray machine the product is sealed in its container. I am having trouble deciding weather this needs to be an additional CCP for foreign material control, the current CCP to these products is PH, we have other controls in place for physical contaminants that have always sufficed for our audits but bringing the X-ray into place i want to make sure that we address it correctly for the HACCP side of things. From other's post on here i know it comes down to the hazard analysis and weather its controlling the hazard/risk any further or getting rid of it all together.I am just not sure weather its considered more of a monitoring activity/PRP or if it needs to be a CCP based off the fact that it is detecting foreign material further than any of our other controls are capable of being that it is x-ray and can see inside of the product whereas we cannot, though the controls prior make it more difficult to occur.

 

Looking at the CCP decision tree i am leaning towards yes it should be a CCP based off of the questions that the decision tree asks but wanted some others insight who may have already dealt with this.

 

Thanks for any and all help!


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#2 Scampi

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Posted 16 May 2018 - 06:18 PM

so 1, have you had an issue is that why it was installed?  (cause they are d*** expensive)

 

I would say NO to CCP if you don't have a historical problem with FM

 

AND a CCP is when no other interventions reduced or eliminated the hazard. Now one would assume that your have sorters, visual inspections et all prior to the fancy new machine that SHOULD reduce the hazard to an acceptable limit prior to xray

 

So it will depend on your risk assessment ( use the tree as a guide, but it doesn't replicate what you know about your process)


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#3 MGB503

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Posted 16 May 2018 - 07:45 PM

Scampi,

 

 

No we have not been having issues, it was a request by a very large customer.... I am hoping to not have to add another CCP into the loop, foreign material is not a big thing for us but it does happen... and you are correct there are others methods in place which reduce the hazard. I just want to be sure my bases are covered for audit time, looking at the decision tree i lean towards CCP every time.. Thought i can side with the fact that other PRP take care of the hazard as well.. Am i understanding correctly that just because it is another step to address a hazard, maybe even further, doesnt necessarily mean it needs to be designated as a CCP?


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#4 Scampi

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Posted 16 May 2018 - 07:52 PM

Ok, well that is good news!

 

The very definition of a CCP is 

"A critical control point (CCP) is defined as a step which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. " Since you have other steps, (and this is a customer request) then I would just add it a either a PC or a CP (process control or control point  BUT not critical)

 

You are not going to put an entire batch on hold becuase the xray found 1 defect that may OR MAY NOT be FM

 

If you were say slicing and dicing and had a metal seive and no employee ever looked at the FG in process (like say canned peaches) then it would have to be a CCP because you have no other steps.

 

So if your new toy shows FM, say 1 time for each 5000 units, I would write the program to just dispose of that one unit and carry on..........if it were a CCP, you'd have to put the entire batch on hold until you figured out what when wrong

 

Hope that helps!


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#5 mgourley

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Posted 16 May 2018 - 08:04 PM

I'd agree with Scampi here.

 

However, you said "foreign material is not a big thing for us but it does happen..."

 

So you should probably go back through your records and determine just how often FM happens. And then make a determination on risk.

 

You should do this stuff anyway, just so you can prove to an auditor that you actually thought about it before you decided to NOT make it a CCP  :shades: 

 

Marshall


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#6 Gerard H.

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Posted 17 May 2018 - 07:04 AM

Hi MBG,

 

By installing the new X-ray machine in the line, you have modified your process. You need to update your HACCP plan consequently (Process flow, risk assessment, creation of procedures, instruction of personnel and carry out a validation of all that).

 

If the risk of the new process step is sufficiently high, then it passes through the decision tree, which will tell you whether it's a CCP or not.

 

I wish you good luck with your new installation!

 

Kind regards,

 

Gerard Heerkens


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