BRC Issue 6 - Clause 4.10.3.5

Our team has received mixed information regarding the interprestion of clause 4.10.3.5 "checks that test the memory/rest function of the metal detector by passing successive test packs through the unit." One auditor has told us that we must pass each test piece (NF, F, SS) throug the detector three times in a row and would ideally have three of each wand, place them in the process flow and then verify the rejection of the unit. Another auditor has told us that all that is necessary is to pass each test piece ONCE (NF, F, SS) to verify they adequatley reject without having a person need to reset the metal detector. If anyone has any further thoughts, I would appreciate hearing what other facilities are doing to comply.

Our team has received mixed information regarding the interprestion of clause 4.10.3.5 "checks that test the memory/rest function of the metal detector by passing successive test packs through the unit." One auditor has told us that we must pass each test piece (NF, F, SS) throug the detector three times in a row and would ideally have three of each wand, place them in the process flow and then verify the rejection of the unit. Another auditor has told us that all that is necessary is to pass each test piece ONCE (NF, F, SS) to verify they adequatley reject without having a person need to reset the metal detector. If anyone has any further thoughts, I would appreciate hearing what other facilities are doing to comply.

Our CCP for metal detection is each wand being ran through three consecutive times. We were advised to this over 18 months ago by our HACCP/BRC consultant. Every auditor we have encountered has made a point of saying what a good idea this is and that is does cover 4.10.3.5. In the long run, whatever different auditors might say, your food safety program is strengthened by this practice. It was a small learning curve ( annoyance) for our staff and a change in paperwork but we feel it is worth it. Best of luck!
Bill

Thank you for bringing this up. I am currently reviewing our SOP on metal detection but I have to admit I missed this subsection and it's made me realise I need to carefully review my SOP with the BRC standard.

I also have to admit we weren't doing this test. The Tesco code of practice describes the memory test as follows:

Product Testing - Memory Test

The test packs should be sent through the metal detector with a standard pack in between (which has already passed through the metal detector). This should be carried out at the start and end of a shift and be documented.

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It is a failed test if any of the test packs are not rejected. If a standard pack is rejected the line must be stopped and the issue should be investigated e.g. timing of reject mechanism.

Although I have to admit rereading that description again, I think it's actually just passing the three test packs through successively at normal production spacing?

Dear All,

I don’t hv the latest BRC versions’s exact requirements however if the “triplicate” step for each wand is somehow statistically inclined, I would like to invite BRC (or any pro-3x auditors) for their validation of such a feature. I can appreciate the logic of a duplicate test since this is a sort of minimal “accuracy” feature of any arbitary measurement but why triplicate ?, surely quadrupling will be even better ?. Or even more BRC-friendly, perhaps the multiplying factor should be quantitatively risk assessed, IMO, the likely conclusion will be a factor of “1” assuming the "calibration" step itself is repeated approximately every hour or so.

This is surely more BRC nonsense related to their financial necessity of a yearly (?) re-issue. And it appears that the auditors are happily, anecdotally, buying in (unless it is genuinely b/w prescribed).

Rgds / Charles.C

We have been running test wands through twice each for years. Never been an issue with our current auditors.

Marshall

We do our daily testing prior to start-up, every two hrs, and also at the end of each run.
I am now planning on doing a monthly check where I send multiple test packets thru to verify all get rejected. I guess I plan on doing this for FE, non-FE, and SS. Do you all believe this is compliant to 4.10.3.5??

Thanks on advance!!

We do our daily testing prior to start-up, every two hrs, and also at the end of each run.
I am now planning on doing a monthly check where I send multiple test packets thru to verify all get rejected. I guess I plan on doing this for FE, non-FE, and SS. Do you all believe this is compliant to 4.10.3.5??

Thanks on advance!!

We test at start up, every hour during extended runs, before each product change over and at the end of the run. During each check we pass each test wand through twice.
This would seem to meet the intent of the clause.
When the interpretation guide comes out, perhaps there will further clarification.

Marshall

I am suprised that I have not seen it yet but I am pretty sure the answer is, DO A RISK ASSESSMENT!

I don't think there is any accepted or documented procedure. We are typically bound more to what our customers want than to any standard. Our suppliers have given us a variety of explanations for how they handle it and I am sure everyone does it different but if you can show that whatever method you choose works for you than an auditor should not be concerned.

For recordand comparison, we do two times each and seem to meet everyones requirements. Testing through the rejection and reset are generally considered critical by most of our customers.

The BRC Best Practice Guideline for Foreign Body Detection that came out in 2008 says that "3 tests per test material type and position would be considered the maximum practical level for production verification purposes. However, where good detection capability has been established during commissioning, one test per test sample material type and position would be considered acceptable practice."

Gail
infoiqc

We do our daily testing prior to start-up, every two hrs, and also at the end of each run.
I am now planning on doing a monthly check where I send multiple test packets thru to verify all get rejected. I guess I plan on doing this for FE, non-FE, and SS. Do you all believe this is compliant to 4.10.3.5??

Thanks on advance!!

Only, if you are able and willing (costs), to recheck all the products from the last good check, when a failure occure.
You should also be able to proof that there were no product changes (size, packaging material, product) within this time period. So you should only make one product in one kind of packaging on the same line.
I am shure that I will challenge this practice.

●● checks that test the memory/reset function of the metal detector by passing successive test packs through the unit.

Do they not mean the reset test during the start of production, in which you send a few packs through the metal detector to set or calibrate the metal detector?

The requirement regarding the test pieces is somewhere else in 4.10.3.5:
●● use of test pieces incorporating a sphere of metal of a known diameter. The test pieces shall be marked with the size and type of test material contained.
●● tests carried out using separate test pieces containing ferrous metal, stainless steel and typically non-ferrous, unless the product is within a foil container.
●● a test that both the detection and rejection mechanisms are working effectively under normal working conditions.
●● the test piece shall be passed as close as possible to the centre of the metal detector aperture and wherever possible be carried out by inserting the test piece within a clearly identified sample pack of the food being produced at the time of the test.