3 replies to this topic

[agnes]

Hi
I really need your help guys as I am struggling now.
I work for a company which packs dry free flowing product into 1 kg bag. The product mean aperture is different depending of the product. Based on that we have different ccp screens in place for each of them (4mm, 5mm, 7mm and 10mm). The screen is in place to prevent physical contamination which can happen some times.
During the last audit - auditor pick up that we can not have so many different ccp screen sizes for different product but the same contamination - and that next time we will receive non-conformance for it if we won’t change it.
I don’t know how to argue it. Please help

[GMO]

Hi
I really need your help guys as I am struggling now.
I work for a company which packs dry free flowing product into 1 kg bag. The product mean aperture is different depending of the product. Based on that we have different ccp screens in place for each of them (4mm, 5mm, 7mm and 10mm). The screen is in place to prevent physical contamination which can happen some times.
During the last audit - auditor pick up that we can not have so many different ccp screen sizes for different product but the same contamination - and that next time we will receive non-conformance for it if we won’t change it.
I don’t know how to argue it. Please help

I don't know how to argue it either! I think it's a sign that the auditor is right if you can't defend something.

Some questions to ask yourselves.

Why do you have the different size screens? Is it because the product can't go through a smaller screen?
What are the likely contaminants? What are there size?
What size of contaminant would make it unsafe? (FDA guidance would suggest 7mm.) Therefore, are the critical limits you've chosen enough to control the hazard? Perhaps not.

I would understand it if you adopt the following approach. There is a foreign body risk of stalks from your raw material (for example) and you've decided that a piece greater or equal to 7mm in size is big enough to cause a customer injury. Therefore, you screen all stock to a minimum screen size of 7mm.

However, for some products it is possible to also exclude lumps of product (for quality reasons) by adopting a finer mesh of 4mm or 5mm; so your critical limit is being sieved to 7mm but for some products you sieve on a finer mesh for quality reasons.

I would say that 10mm is far too big though and ideally you should use the finest mesh you can for all products. That said, I know it's not always practicable, for example granary flours you'd just sieve out the wheaty bits if you went too fine!

If I was a customer and I found a foreign body and you told me you sieve to 10mm, I would tell you it's a waste of time! I'd probably feel pretty similar with a 7mm sieve tbh but at least I could understand the justification.

[faisal rafique]

It all depends upon your product consumption age groups as you mentioned in HACCP plans and also FDA regulation in which you can not go more than 7mm foreign matter. Justify the different sieve size according to products but you can not go more than regulation limit.

[Charles.C]

Dear Agnes,

Technically, I would think the US-7mm bogy (hard, sharp objects) is only strictly relevant if you are faced with an American legislative CCP restriction. If otherwise, it becomes a matter of opinion (IMHO), eg what other limiting opinions exist for yr product type/end-user application (if any ). (in fact, even tighter restrictions might be possible if vulnerable end-users are involved)

(for general situation, try this review -
 foreign material contamination.pdf   286.24KB   120 downloads )

As a corollary to GMO's post and if you are concerned about 7mm limit, one possible option may be to downgrade the hazard risk status. For example if yr data shows that the likelihood of any material >7mm passing through the screen is genuinely "negligible" the "probability of something "large" reaching the finished product" is presumably very low. For most HACCP plans, L x H (or VLxH) is not a significant hazard. Additionally i believe you can also find some published examples where the severity will only be typically rated as "M" (CFIA from memory for one) which makes a downgrade even easier .You could then justify making it a prerequisite if you wish to retain the specific "activity" within the haccp plan.

I also suspect that you can find various, quotable, published haccp plans which simply regard screening like this as a typical prerequisite anyway, without worrying about the US-7mm worries. A similar approach can be found in the literature in many haccp plans for the handling of "allergens", a recognised hazard, it often depends on how you conceptually design yr haccp plan for some tricky situations. Plus it may depend on the auditorial reactions to having a possible NC snatched away.

Rgds / Charles.C