15 replies to this topic

[garryrana72]

Hi team, just a basic question, if a metal detector is a CCP, what is the deviation, rejection of the product or not detection of the test bars? It may sound silly but I am confused.
Thanks,
Garry

[AS NUR]

Hi team, just a basic question, if a metal detector is a CCP, what is the deviation, rejection of the product or not detection of the test bars? It may sound silly but I am confused.
Thanks,
Garry

the deviation is how well your MD run. first you have to validate that your MD suitable for your product, Sometimes MD cant run well in liquid can product. second you need verify your MD frequently, and you must use test bar ( standard) to verify your MD, so you can make sure your MD always run well.

Hope can reduce your confuse


rgds

AS Nur

[KTD]

Successful/unsuccessful detection of the test bars/wands etc. is a calibration check. Unsuccessful wand detection would result in stopping production and placing all product back to the last good check on HOLD pending running through a properly calibrated and operating MD. You can continue processing after identifying and addressing the root cause, but all product would have to be placed on HOLD as above - some auditors and regulatory agencies do not allow this.
Deviation would be missing a metallic FM that was identified downstream.
Rejection of contaminated product indicates MD is doing it's job.

Some argue that a finding is a deviation, but IMO, you have acknowledged metal as reasonably likely to occur (or the MD would not be a CCP). It's in how you word the Hazard Analysis...


A tangential question is how can MD be a CCP - it is not a process step...it does not affect the product. I think there may be a discussion thread on that elsewhere...

[Dr Ajay Shah]

Metal detectors (MD) need to be verified frequently and it is better to do that using the test pieces for Non Ferrous, Ferrous and stainless steel as this will be your ctitical limits for detection. The MD needs to be calibrated at least 6 monthly if not on an annual basis by the MD supplier to check that the phase of the detector is operating correctly. Large organisations such as Nestle, Kraft on conducting their risk assessment do say that MD is a CCP as it is counted a part of the process step. In many instances products such as powders fall through the chute and this is surrounded by a MD so that is infact a CCP as it is part of the process.

I may have started a deabate on this topic.!!

[Charles.C]

Dear All,

Minor

the deviation is how well your MD run. first you have to validate that your MD suitable for your product, Sometimes MD cant run well in liquid can product. second you need verify your MD frequently, and you must use test bar ( standard) to verify your MD, so you can make sure your MD always run well.

Hope can reduce your confuse

I initially interpreted MD as Managing Director. The test bar was intriguing.

Rgds / Charles.C

@ Dr Ajay Shah -

The MD needs to be calibrated at least 6 monthly if not on an annual basis by the MD supplier to check that the phase of the detector is operating correctly.

Not exactly sure what 'phase' means but from the point of view of corrective actions many factories (most?) calibrate every day or even more frequently

@KTD -

A tangential question is how can MD be a CCP - it is not a process step...it does not affect the product. I think there may be a discussion thread on that elsewhere...

Yes there is, the one with 10,000 + views

[garryrana72]

Thanks all, I am not debating for MD as a CCP, I am considering it as a CCP. Now again, to keep the things simple, what will be my hazard:-" failure to remove unacceptable product" or "possible metal contamination from equip. etc." & what will be the deviation :- non rejection of the test bars (during my hourly ckecks) or rejection of my product. My deviation will decide my corrective actions i.e. if the deviation is non rejection of test bar, my corrective action will be to work on metal detector (calibration etc.) & taking care of my product since the last good test. But if the deviation is rejection of the product, I will have to investigate the source etc. Hope I am clear
Thanks

[GMO]

IMO the hazard is "persistence (or presence) of metal in the product due to failure of the metal detection equipment", I think that was what you were asking? Your monitoring is then using a test wand and failure of this monitoring should lead to hold of product since last good check etc.

The rejected products should obviously be investigated as part of your controls on metal to ensure a part of your plant isn't deteriorating or that an ingredient isn't coming in contaminated but if you had one reject containing metal, it's not necessarily "stop the plant immediately" time, (depending on what it is). If you have 20 in 5 minutes, perhaps it is...

Edited by GMO, 24 February 2011 - 03:29 PM.

[mgourley]

Thanks all, I am not debating for MD as a CCP, I am considering it as a CCP. Now again, to keep the things simple, what will be my hazard:-" failure to remove unacceptable product" or "possible metal contamination from equip. etc." & what will be the deviation :- non rejection of the test bars (during my hourly ckecks) or rejection of my product. My deviation will decide my corrective actions i.e. if the deviation is non rejection of test bar, my corrective action will be to work on metal detector (calibration etc.) & taking care of my product since the last good test. But if the deviation is rejection of the product, I will have to investigate the source etc. Hope I am clear
Thanks

Your deviation will be any time the metal detector does not properly detect and reject your test wands. You will also have a deviation if the metal detector is not checked according to the schedule you have put in place, or if the procedure to check the metal detector is not properly followed.
Product that is rejected should be inspected for presence of metal. I assume you will also have in place a procedure to do that.
If metal is found in the rejected product, you should have a procedure in place to determine how and why the contaminate came to be in the product.

See attached Deviation Form

Attached Files

•  Metal Detector Deviation Form.doc   31.5KB   295 downloads

[Charles.C]

Dear garryrana72,

I think yr query regarding the "hazard" aspect of a metal detector is probably the single most popular question on this forum.

Auditorially, there are at least 3 seemingly equally acceptable variants of which yr preference is one and perhaps the least likely to create argument. You will see the others if you search a little (or be happy to find one satisfactory choice .)

One thread has also (auditorially) successfully argued that in many cases, the metal detector is not a CCP at all. But it did apparently require argument.

Rgds / Charles.C

[Jules]

I have considered that this process step is "pass product through a verified metal detector" - shortened to metal detection. Accepting that with your process metal detection is a CCP then the following are deviations:

1. Not passing product through the metal detector - possible down some production lines MAJOR

2. Failure to verify that the metal detector is fully functioning - this would be missing a or some verification checks.

3. Failure on the metal detectors part to detect metal, this would be your wands (test pieces) not triggering the reject mechanism.

4. Some customers require that packs detected as containing metal are rejected into a locked bin, a deviation there would be that the bin was not locked or in fact was locked and so full of product that suspect packages are incapable of being rejected.

5. A further deviation could be that the metal detector is triggering the reject mechanism too readily, a further deviation at this point may be that the personnel operating this procedure consider that it is ok to remove the rejected packs to the line - as obviously the metal detector is at fault not the product.

The "phase" discussed earlier is the phase angle that the metal detector is set up with - Technical talk - but suffice it to say that differing products require different phase angles, not being at work I haven't got my crib sheet but it depends on whether the product is perceived as wet or dry. Old analogue metal detectors were set to wet or dry products.

Rather than considering the deviations at metal detection, why not consider what a good job looks like to start off with and use that to audit against what is occurring - i.e. audit against a procedure.

I think I must have bored you all on this subject, time to scan about for another one to pontificate about. BRC audit due and these subjects are favourite night time discussions for me.

I must get a life

Regards Jules

[Charles.C]

Dear Jules,

Enjoyable and perceptive post

Excessive sleep is bad for the digestion.

Rgds / Charles.C

PS In case I forgot, welcome to the Forum !

[garryrana72]

Thanks all,
I am going with the concept that "If a metal detector rejects a product/ package, it is not a deviation, it shows that the metal detector is working". There are some interesting links:
http://www.fda.gov/F...e/ucm119896.htm
http://seafood.ucdav...lans/metal1.htm
seafoodhaccp.cornell.edu/purple_pdf/Ch20.pdf
All these take a different approach. Here emphasis is given that if a metal detector is a CCP, all the product passes through a "verified metal detector" & checking of test pieces is a verification process.
Now the issue which I am facing at my work is that we have defined our deviation as "If the MD doesn't detect test pieces during the hourly checks, take corrective actions" rather than- "if metal detector rejects a pouch, take corrective actions" and in our monitoring, we are checking the test pieces at the start & end of the shift, every 1 hour & when the product size changes (Though we have defined what action are to be taken in case the metal detector rejects product in one of our SOPs)
So, the operators are making sure that the metal detectors are working perfectly (as deviation will cause CCP deviation) but are less sensitive if a pouch is rejected (as CCP is not deviated) hence our metal detectors are working perfectly but I am not confident that every pouch is passing through the MDs and the guys are seriously investigating the cause of the rejection rather than segregating the pouch and running the machine again. Hope I am not confusing every one though I am trying to be very simple & attacking the fundamental issue.
Thanks

[Charles.C]

Dear garryrana72,

Nice colour scheme.

Perhaps the last post is not representative but i could imagine some auditors commenting that most haccp discussions include terms like "hazard" and "critical limits" here and there.

Rgds / Charles.C

[mgourley]

So, the operators are making sure that the metal detectors are working perfectly (as deviation will cause CCP deviation) but are less sensitive if a pouch is rejected (as CCP is not deviated) hence our metal detectors are working perfectly but I am not confident that every pouch is passing through the MDs and the guys are seriously investigating the cause of the rejection rather than segregating the pouch and running the machine again. Hope I am not confusing every one though I am trying to be very simple & attacking the fundamental issue.
Thanks

You should have a procedure in place that will "make" the operators investigate the cause for product rejection. There must be "some" reason why some product is getting rejected.

[GMO]

You should have a procedure in place that will "make" the operators investigate the cause for product rejection. There must be "some" reason why some product is getting rejected.

I'm always wary about getting operators to do this. IME, the investigation will be (best case) putting it back on the line before the metal detector and if it gets rejected putting it in the bin or (worst case) putting it back on the line after the metal detector.

Maybe I'm just untrusting.

Personally I would rather rejects waited until someone more senior or more technical came along and investigated them unless you have a very good set of operators you can fully trust with taking something which is a reject and investigating it; normally this will involve putting it back on the line at least 3 times and breaking the product down and it will be a huge temptation for a busy operator just to stick it back on and if it goes through to let it lie...

[Georgina]

Hi team, just a basic question, if a metal detector is a CCP, what is the deviation, rejection of the product or not detection of the test bars?

Hello, Garry!
In the experience I have with this CCP, is that both cases you mention are the deviations to consider.
The explanation is the next one:
- No rejection: Even if your metal detector is detecting the test bars, your contaminated product is not being stopped. So in case this fails to work, you have a potentially unsafe product.
- No detection of the bars: This is your metal detector is not identiying the metals inside it, so here you also have potentially unsafe product.

In the plant where I work, both cases are considered critical and they generate corrections and corrective actions. The product is stopped from the last approved monitoring and processed again through a metal detector with the same detection level.

Hope this helps for your doubt.

Regards,
Carmengina