Dear Charlorne,
I agree the CL is a debated issue (see other threads in this forum) and that there is flexibility however I think you have found a nice auditor (or you are one). Mine's typical comment would be 'must specify'. I think many people write the MD machine standard's values assuming they look good enough as compared to, for example
http://www.cfsan.fda...s/haccp-2t.html
(the next version became a bit less exact) see -
http://www.cfsan.fda...mm/haccp4t.html
Perhaps I've been unlucky with auditors.
Rgds / Charles.C
added - another presentation variation could be like this (step 27) -
http://www.inspectio...hamjam10e.shtml
Hi Charles,
I am not agree with the
HACCP plan in your first link (From 1998). The Corrective Action column describe a Correction not a corrective action. This is from ISO-15161:2001...
The concept of corrective action in the HACCP method describes the processing of nonconforming products and the nonconformities and the correction of the situation. The concept of corrective action in ISO 9001 -(an now also with ISO-2200)- is based on searching for causes in such a way as to perpetuate the elimination of the problem at the source of the nonconformity.
Also I am not agree with the monitoring Frequency.
Metal Detector are usually monitored with std spheres every hour or at least twice a shift. (a similar situation is described in the Verification column).
Verification is usually performed with internal audits, inspections, supervision, etc.
This is From ISOTS-22004
The validation usually includes such activities as:
a) reference to validations carried out by others, to scientific literature, or to historical knowledge,
b) experimental trials to simulate process conditions,
c) biological, chemical and physical hazard data collected during normal operating conditions,
d) statistically designed surveys,
e) mathematical modelling, and
f) use of a guide approved by competent authorities.
Metal detector validation are usually performed with a test with various materials: (304 SS, Nickel, Brass, Chrome steel, etc) Evaluation are performed in order to assess if the device and the rejecting system is capable of deflect metal particles of different characteristics. This could be considered as b) (experimental trial to simulate process condition).
Monitoring is usually performed with SS and ferrous metal and is performed in order to challenge the device and the system surround them.
Saludos.