Sorting and sieving control point

i work in a cereal bar production factory and we have hand sorting as a control step that removes all foreign matter received with raw materials . We are working on our HACCP study and what i want to know is can we have the sorting step as a CCP? According to the decision tree, the 2 yes lead it to a CCP but since it is human hand sorting, how do you validate the CCP?Please help!

Hi tech,

The problem for your setting the hand sorting as a CCP is that could it minimize the foreign body hazard in cereal?

Why do not you set a sieving process?

And according to BRC standards, producer is responsible for due diligence. Thus a foreign body removing equipment should be introduced to enhance the assurance of your products.

Best regards,

Jason

Yah, in sorting we remove all the stones, glass, hair etc that comes in with the raw materials like nuts, dried fruits etc.Foreign matter removed is actually smaller than the raw material such that sieving wont help. Hand sorting is actually efficient judging from the customer complaimts but now we need a validation record for it to be a CCP.

It's very difficult to be a CCP due to the fact that humans are fallible. You would need to have some visual standards IMO but if these pieces are smaller than the sieve, is it really a safety risk or a quality one?

Sorry, can't write a long answer because my son's in his bouncer and wanting attention!

I guess any equipment which separates product according to density difference will be suitable for your sorting operation. There is always density difference exist in foreign material like stone and a nut. The only thing you have to do is search such kind of equipment. I am not 100% sure that it will solve your problem but that will be possible solution.

Dave

i work in a cereal bar production factory and we have hand sorting as a control step that removes all foreign matter received with raw materials . We are working on our HACCP study and what i want to know is can we have the sorting step as a CCP? According to the decision tree, the 2 yes lead it to a CCP but since it is human hand sorting, how do you validate the CCP?Please help!

Seems like a prerequisite to me. Do you have clearly defined measureable critical limits?

Regards,

Tony

Yah, in sorting we remove all the stones, glass, hair etc that comes in with the raw materials like nuts, dried fruits etc.Foreign matter removed is actually smaller than the raw material such that sieving wont help. Hand sorting is actually efficient judging from the customer complaimts but now we need a validation record for it to be a CCP.

Hi tech,

I agree with Toy.C that you could set the sorting process as the PRP.

However, the problem for manual sorting is that are you sure you can well control the activity of workers? So the risk of foreign body hazards still exist.

If you insist on setting this as your CCP(According to decision tree I guess it can be a CCP), you should validated the Cl of this CCP to ensure that it will not remain the hazard in further processes.

By the way, finding and removing the foreign bodies such as hair from the products is not a easy thing.

By validation, you could conduct and record the below activity:

1, Firstly intentionally add the foreign bodies into an amount of cereal
2, Ask some workers to sort out the added foreign bodies from the cereal
3, After sorting, checking the remaining foreign bodies in such cereal

note:

1, I have no idea how many times this activity should be repeated, but only once done is not sufficient to convince people
2, The sorting time should also be controlled, if sorting out all foreign bodies cost you quite a long time, it is not feasible to introduce it into the real production.
3, Worker is not a machine, thus after a period of sorting, visual sighting and sensability of workers will definitely decrease. Thus the consistent of work is a inevitable problem to be faced by you.

Just my five cents opinion,

Best regards,

Jason

Dear All,

It depends on the risk analysis as usual and i suppose this product may be "sensitive" but for some flowcharts this step might not even reach prerequisite status (assuming yr risk matrix permits a lower level )

Rgds / Charles.C

Be wary of relying on a decision tree to decide CCPs. Some of them will identify obvious prerequisites as CCPs; glass control for example. You have to use it with care, there are alternatives available which have an additional question about "is there an existing PRP which controls the hazard" but IMO they also have their downsides, how, for example, did you decide the PRP should be a PRP anyway?! Decision trees are an aid but they're no substitute for knowledge, experience and the team's opinion based upon this.

Hi Jason
Thnks very much for your feed back, we currently had our HACCP audit having this step as a CCP and we had a problem in this validation. The CCP was deemed as failing as customer complaints were indicating that foreign objects are passing through. You know with people the auditor was saying we need to do eye tests and also consider people moods etc.

Now for our corrective action we are considering converting this step into a PRP but my questions are:
1) Almost all the raw materials we receive have foreign matter eg stones, pitts when we receive them
2) The sorting step has been included solely to remove these foreign objects
now looking at severity these foreign objects can range fron moderate to high risk and probability of occurence is common repeating or high, How do i justify this step to being a PRP?

Thanks

Hi tech,

I agree with Toy.C that you could set the sorting process as the PRP.

However, the problem for manual sorting is that are you sure you can well control the activity of workers? So the risk of foreign body hazards still exist.

If you insist on setting this as your CCP(According to decision tree I guess it can be a CCP), you should validated the Cl of this CCP to ensure that it will not remain the hazard in further processes.

By the way, finding and removing the foreign bodies such as hair from the products is not a easy thing.

By validation, you could conduct and record the below activity:

1, Firstly intentionally add the foreign bodies into an amount of cereal
2, Ask some workers to sort out the added foreign bodies from the cereal
3, After sorting, checking the remaining foreign bodies in such cereal

note:

1, I have no idea how many times this activity should be repeated, but only once done is not sufficient to convince people
2, The sorting time should also be controlled, if sorting out all foreign bodies cost you quite a long time, it is not feasible to introduce it into the real production.
3, Worker is not a machine, thus after a period of sorting, visual sighting and sensability of workers will definitely decrease. Thus the consistent of work is a inevitable problem to be faced by you.

Just my five cents opinion,

Best regards,

Jason

Charles

Thanks, the risk analysis rates the hazards as high risk and common repeating as we can find glass as well in the cereals and the products are for people from 4 years and older.

We permit no foreign matter in the finished product or we are being tough to ourselves? we use nuts and i mean pitts are a natural part of fruits although they are uncomfortable to bite into offcourse

Dear All,

It depends on the risk analysis as usual and i suppose this product may be "sensitive" but for some flowcharts this step might not even reach prerequisite status (assuming yr risk matrix permits a lower level )

Rgds / Charles.C

Thanks fellow, how is the son ?
Yah u right we just had our HACCP audit and the contest was on the fact that the people are fallible. Now i am looking at making it a CCP but my problem is that the foreign matter being removed at this step if moderate in severity but probability of occurence is high how do i justify to just being a PRP{ instead of a CCP?

Regards

It's very difficult to be a CCP due to the fact that humans are fallible. You would need to have some visual standards IMO but if these pieces are smaller than the sieve, is it really a safety risk or a quality one?

Sorry, can't write a long answer because my son's in his bouncer and wanting attention!

Problem there again Tony, our customer requires to have no foreign matter in the finished product and since its eyes checking really it is difficult to measure their efficiency. I am also now beginning to think this should be a PRP but now considering that this is the only step that has been established to be removing all the foreign matter that comes in with the raw materials after which no further step is in place to remove the stones, how do i then justify this step as a PRP.

Thanks

Seems like a prerequisite to me. Do you have clearly defined measureable critical limits?

Regards,

Tony

Problem there again Tony, our customer requires to have no foreign matter in the finished product and since its eyes checking really it is difficult to measure their efficiency. I am also now beginning to think this should be a PRP but now considering that this is the only step that has been established to be removing all the foreign matter that comes in with the raw materials after which no further step is in place to remove the stones, how do i then justify this step as a PRP.

Thanks

Hi Tech,

Firstly if you are getting excessive stones, glass, hair etc coming in with the raw materials like nuts, dried fruits etc. then you need to look at your supplier assurance system and purchasing specifications.

I agree with your view that this step can be considered a CCP in that it is the only step that removes the hazard. The problem is the control measure in itself is not effective and you have evidence that it is not effective.

To me this means you need a more effective way of screening, as Jason has stated "Thus a foreign body removing equipment should be introduced." If this was after the sorting then this would be the CCP and far easier to validate.

Regards,

Tony

Sorry for replying so late, all due to my busy work in last month

Well, if BRC audit is conducted now, and the representative of factory tell me that they can not solve this problem by sorting process. At least two NCs will be raised by me

1, CCP monitoring procedure can not ensure the critical limit of foreign body issue(according to COMPLIANCE POLICY GUIDE section 555.425, dimension of sharp foreign body within the scope of 7-25mm).
2, Senior management can not provide sufficient resource to ensure the adequate safety level of product(Because based on fact of complaint and your current monitoring procedure, it is believed that your factory urgently need a foreign body detector to deal with the situation).

So just as Tony posted above, I propose if possible you can invest a "machine keeper" to prevent such contamination from your products.

Best regards,
Jason

Thanks tony for the sound advice, u are a genius! I think what we have to do now is to look into investing in a suitable screening machine and making sorting an oPRP. Suppliers, they will give specs that say free from foreign matter while in actual the product does have and with farming practices thats some milestone to go.

Thanks

Regards

Tech

Hi Tech,

Firstly if you are getting excessive stones, glass, hair etc coming in with the raw materials like nuts, dried fruits etc. then you need to look at your supplier assurance system and purchasing specifications.

I agree with your view that this step can be considered a CCP in that it is the only step that removes the hazard. The problem is the control measure in itself is not effective and you have evidence that it is not effective.

To me this means you need a more effective way of screening, as Jason has stated "Thus a foreign body removing equipment should be introduced." If this was after the sorting then this would be the CCP and far easier to validate.

Regards,

Tony

Thanks Jas, apology accepted u will never know how much your feedback has helped me. U guys sound really seasoned in food safety matters and its a bonus to have you in the forum, hats off . We will in the long term buy an X- ray machine but we will convert the sorting step into an oPRP, try and improve efficiency by tripple sorts, staff rotation, the sorting monitoring as you suggested etc. i know it will take time but will at least reduce error.

Thanks a bunch!

Regards

Tech

Sorry for replying so late, all due to my busy work in last month

Well, if BRC audit is conducted now, and the representative of factory tell me that they can not solve this problem by sorting process. At least two NCs will be raised by me

1, CCP monitoring procedure can not ensure the critical limit of foreign body issue(according to COMPLIANCE POLICY GUIDE section 555.425, dimension of sharp foreign body within the scope of 7-25mm).
2, Senior management can not provide sufficient resource to ensure the adequate safety level of product(Because based on fact of complaint and your current monitoring procedure, it is believed that your factory urgently need a foreign body detector to deal with the situation).

So just as Tony posted above, I propose if possible you can invest a "machine keeper" to prevent such contamination from your products.

Best regards,
Jason

Dear tech,

we will convert the sorting step into an oPRP

I trust you appreciate that the BRC standard has no interest in OPRPs. Plus you are anyway required to justify / validate them.

As Tony-C pointed out, yr basic problem is that the control measure does not presently qualify as effective. Plus it sounds like yr finished product specs. are simply unrealistic if nil tolerance of any contamination, however that is not necessarily a safety criterion unless for example there are large amounts of glass fragments. As already noted, this would imply a serious supply problem.

If the famous 7mm is auditorially acceptable as a max. safety critical limit, I would hv thought a few sieves would easily solve yr basic haccp problem (or an investment in some plastic spectacles )Glass is perhaps a different matter in view of yr intended consumers.


Rgds / Charles.C

Dear Charles,

Well, COMPLIANCE POLICY Section 555.425 is the only literature as I know to stapulate the requirement on dimension of sharp foreign body in food. Such document usually used to conduct the validation of CCP/Cl concerning foreign body hazard I guess. Furthermore at least it seem in China, no similar document observed by me. If you know the up-to-date document, would you like to share with us ?

On the other hand, retail seems prefer the minimal dimension of foreign body as same as the maximual sensitivity of the state-of-art foreign body detector. Thus, if suppliers want to sell their products to retail, normally they will try their best to control the foreign body in their products.

So I do not think 7-25mm requirement is conflicting with the retail requirement. If both exist in one factory. It is obvious the most restrict specification(retail requirement) should be considered in the HACCP Plan.

By the way, if purchaser of the factory also agree with the 7-25mm foreign bodies, it will not be a problem when they establish and implement a control measure.

Above is just my five cent opinion

Best regards,

Jason

Hi Charles
Yeah you are right, the step still needs to be validated. At least when its a oprp i will not need to define the critical limit, which i cant.

Our customer specification is nil contamination and is it possible to have a limit that is 7mm which is acceptable as a safety critical limit but list on specification nil contamination?

In that case i should believe it will be fairly easy to validate the step using the customer complaints as there are none beyond the 7mm or with glass. now with sieving some of the raw materials are diced fruits like apricots and the foreign objects will just stick to the fruit. what do u think Charles?

Regards

Tech
I trust you appreciate that the BRC standard has no interest in OPRPs. Plus you are anyway required to justify / validate them.

As Tony-C pointed out, yr basic problem is that the control measure does not presently qualify as effective. Plus it sounds like yr finished product specs. are simply unrealistic if nil tolerance of any contamination, however that is not necessarily a safety criterion unless for example there are large amounts of glass fragments. As already noted, this would imply a serious supply problem.

If the famous 7mm is auditorially acceptable as a max. safety critical limit, I would hv thought a few sieves would easily solve yr basic haccp problem (or an investment in some plastic spectacles )Glass is perhaps a different matter in view of yr intended consumers.


Rgds / Charles.C
[/quote]

Hi Jason,
Another question buddy, how do i review my HACCP plan. i have changed one of the process flow layout and need to review the HACCP sudy, which documents are affected and which additional records must i keep. how do i in a documented way, initiate the review. i know i have to do the hazard analysis for the new layout but if there is no new hazard introduced where do i capture this in the HACCP study documentation?

Phew, yeah amateurs growing up in the system please assist.

NB. U must say jus ur million dollar opinion!

Regards

Tech

Dear Charles,

Well, COMPLIANCE POLICY Section 555.425 is the only literature as I know to stapulate the requirement on dimension of sharp foreign body in food. Such document usually used to conduct the validation of CCP/Cl concerning foreign body hazard I guess. Furthermore at least it seem in China, no similar document observed by me. If you know the up-to-date document, would you like to share with us ?

On the other hand, retail seems prefer the minimal dimension of foreign body as same as the maximual sensitivity of the state-of-art foreign body detector. Thus, if suppliers want to sell their products to retail, normally they will try their best to control the foreign body in their products.

So I do not think 7-25mm requirement is conflicting with the retail requirement. If both exist in one factory. It is obvious the most restrict specification(retail requirement) should be considered in the HACCP Plan.

By the way, if purchaser of the factory also agree with the 7-25mm foreign bodies, it will not be a problem when they establish and implement a control measure.

Above is just my five cent opinion

Best regards,

Jason

I would have a meeting and minute that meeting, then even if very little is changed, you can prove you have considered it as a team and made the changes you need to.

Just back on your comments on x-rays; I know I say this all the time but be aware that they're not perfect and are in fact best at detecting metal. It depends on the density difference between what you're looking for and the contaminant. I remember complaining to a company about stones in dates and they said they'd tried x-ray and it didn't work.

I would like to be the Number 100 person to click "Thanks" Button to you, GMO You always the light on this forum .

About the review process to HACCP system, I agree with you so much. In China, when teammember want to review the HACCP Plan, they will conduct a meeting called HACCP team member activity meeting and finally make a record for all disscussions and conclusion of such meeting. According to conclusion, they will decided whether to adapt the HACCP Plan or not.

Best regards,

Jason

Hi GMO
Great, Thanks GMO i see what you mean . Now talking of stones in dates, coz we also have that problem, pitts more, what sizes would you consider as food safe? Offcourse it is unpleasant to find a stone in your cereal bar but does it really mean finding a 3mm stone renders the product unsafe for a population of 4years and older?

Regards

Tech

I would have a meeting and minute that meeting, then even if very little is changed, you can prove you have considered it as a team and made the changes you need to.

Just back on your comments on x-rays; I know I say this all the time but be aware that they're not perfect and are in fact best at detecting metal. It depends on the density difference between what you're looking for and the contaminant. I remember complaining to a company about stones in dates and they said they'd tried x-ray and it didn't work.

Hi Charles
Yeah you are right, the step still needs to be validated. At least when its a oprp i will not need to define the critical limit, which i cant.

Our customer specification is nil contamination and is it possible to have a limit that is 7mm which is acceptable as a safety critical limit but list on specification nil contamination?

In that case i should believe it will be fairly easy to validate the step using the customer complaints as there are none beyond the 7mm or with glass. now with sieving some of the raw materials are diced fruits like apricots and the foreign objects will just stick to the fruit. what do u think Charles?

Regards

Tech