19 replies to this topic

[Kellio]

Question?



We are Frozen Vegetable Packaging Plant. I am updateing our HACCP Plan and we always had one CCP which is the Metal detector. Now, we have 2 metal detectors, one for bags and one for cases. Is it fair to say that we have 2 CCP's now? Due to they are located apart in the production line.


Any advise would be greatly appreciated.



Thank you

[Madam A. D-tor]

Dear Kellio,

I would say that you have still 1 CCP. Which is situated in 2 different packing processes. Probably the hazards you are controlling with this CCPS are the same for both processes.

It does actually not matter, if you name it 1 or 2 CCPs. What is in a name? You need to control them.

[Kellio]

Let me Clarify.


We have multiple production lines and each line have 2 metal detectors. Each production line has one for bags with a rejection system and one to check cases with bags inside the cases. So, If I understood correctly, since both metal detectors are checking for metal, I would still have one CCP.



Thank you for your response.

Dear Kellio,

I would say that you have still 1 CCP. Which is situated in 2 different packing processes. Probably the hazards you are controlling with this CCPS are the same for both processes.

It does actually not matter, if you name it 1 or 2 CCPs. What is in a name? You need to control them.

[Madam A. D-tor]

If they are both in the same line, meaning they are both in use when processing and both are inspecting the same products, then I wood say the most critical is the CCP.
Then again you should check both metal detectors in the same way, so it actually does not matter if you call only one of them a CCP or if you determine them both as a CCP.

Can you explain why you are using 2 metal detectors in line. Is there a possibility to include metal in the case if the bags are closed? Or do you perhaps inspect the product from another angle to make the detection more specific? For example to detect small wires?

[Kellio]

Yes. both are cheking the same product during production. Bags first and and when the bags are packaged into the case.

They main reason we have 2 metal detectors per line is because we deal mainly with already cut frozen vegetalbles in bulk and we package them for different customers (or Labels) for retail. Due to issues with foreing material (mostly Metal) in the past, our Company decided to install the second metal detector in all the lines to control metal contamination to ensure food safety..

Thank you for your help.

[psunjka]

I don't know how it works in Netherlands but in Canada we definitely strive to have less CCPs because the level of inspection will be lower. In your case (we have a similar problem, multiple metal detectors spread out accross departments and lines) we named it as one CCP, at various positions. For every HACCP plan we have one metal detector CCP, but the hazard can be controlled at one or more metal detectors.

[Kellio]

Thank you for your response. I understand the concept. I agree the less CCP's the better. Just looking for clarification.

I don't know how it works in Netherlands but in Canada we definitely strive to have less CCPs because the level of inspection will be lower. In your case (we have a similar problem, multiple metal detectors spread out accross departments and lines) we named it as one CCP, at various positions. For every HACCP plan we have one metal detector CCP, but the hazard can be controlled at one or more metal detectors.

[Madam A. D-tor]

I don't know how it works in Netherlands but in Canada we definitely strive to have less CCPs because the level of inspection will be lower. In your case (we have a similar problem, multiple metal detectors spread out accross departments and lines) we named it as one CCP, at various positions. For every HACCP plan we have one metal detector CCP, but the hazard can be controlled at one or more metal detectors.

That is exactly what I tried to illustrate, but probably I need more words and it is only confusing people. Thanks for clarifying.

[StuartMarriott]

Hi Kellio

I understand your system as: 1 Metal detector checking individual packs of frozen vegetables and then a second that checks the finished case, which contains more than one pack.

In this instance:

METAL DETECTOR 1: This is checking the primary pack - this will be a CCP

METAL DETECTOR 2: UNLESS the packs checked by detector 1 are not sealed, or have been reopened and sealed after detector 1, this step should not be a CCP. (if the bags are not sealed, or need to be reopened after MD1, then MD1 may not be situated in the 'correct' place)

What is the risk to the actual product from contamination within the case?

Why is there a MD for the case? is there a genuine risk of metal becoming associated?

If MD2 is genuinely required it is maybe more of an engineering support function, rather than food safety i.e. shows you when machines are starting to breakdown, rather than identifies metal contamination of the physical product.

Stuart

[Barrie@RJT]

I'd be inclined to refer to your combined efforts to prevent metal contamination as an OPRP? Even less CCPs then.....!!?

[Cravin' Cajun?]

At my facility (cane sugar refinery), we have 5 metal detectors, due to the different packaging sizes, but only 1 CCP (metal detection)...this was approved of by the BRC auditor when we went through certification last year...we label them 1A, 1B, 1C, 1D, and 1E on our process flow diagrams, and in my food safety training for all new hires, it is discussed as "one type of CCP, but 5 devices". Does that make sense?

[Kellio]

Thank you!!!

It makes a lot of sense now after reading all the comments and inputs.



You do not how much I appretiate all this information.

At my facility (cane sugar refinery), we have 5 metal detectors, due to the different packaging sizes, but only 1 CCP (metal detection)...this was approved of by the BRC auditor when we went through certification last year...we label them 1A, 1B, 1C, 1D, and 1E on our process flow diagrams, and in my food safety training for all new hires, it is discussed as "one type of CCP, but 5 devices". Does that make sense?

[Kellio]

Thank you for your input!!!

MD1 is for our primary pack - bag - They are alraedy sealed and packed into a case. (e.g. 6 bags per case)

MD2 is for our secondary pack - case - once the bags are packed into the case; then, passes through the 2nd Metal detector. (I guess this step was created due to a lot of issues with metal. Consider it a safety net.)

The primary risk is metal from the supplier; but, also from our enviroment and equipment as well.

Hi Kellio

I understand your system as: 1 Metal detector checking individual packs of frozen vegetables and then a second that checks the finished case, which contains more than one pack.

In this instance:

METAL DETECTOR 1: This is checking the primary pack - this will be a CCP

METAL DETECTOR 2: UNLESS the packs checked by detector 1 are not sealed, or have been reopened and sealed after detector 1, this step should not be a CCP. (if the bags are not sealed, or need to be reopened after MD1, then MD1 may not be situated in the 'correct' place)

What is the risk to the actual product from contamination within the case?

Why is there a MD for the case? is there a genuine risk of metal becoming associated?

If MD2 is genuinely required it is maybe more of an engineering support function, rather than food safety i.e. shows you when machines are starting to breakdown, rather than identifies metal contamination of the physical product.

Stuart

[Charles.C]

Dear All,

As i understand the 2 metal detectors referred are (closely) in series.

I also assume the detection capability of each MD unit is equal (should be validated and I suspect in practice may not be true (?)).

If so it is a convention in traditional haccp that the location of the second (final) unit is regarded as the CCP (ref. probably available if interested).(and also intuitively "logical" on a risk assessed basis in the hazard analysis).
Philosophically the issue is, and has been, debated many times (eg should remove contamination as early as possible ?) however the criterion of minimising the number of CCPs normally takes priority.

There are a few other threads here for series of (back-up) filters where a similar (but more debatably complicated ) issue arises.

Rgds / Charles.C

[Madam A. D-tor]

Dear Charles,

I agree with you that in HACCP-studies the latest control measure is normally the CCP. In this case the first metal detector, which is detecting individually bags, is probably more accurate ( I mean can detect smaller pieces) then the second one, which is detecting 6 bags in a case.

But like I wrote before, I believe it actually does not matter if you:
1) determine one of the metal detectors a CCP and the other not;
2) determine both of the metal detectors a CCP and number them as CCP 1 and CCP 2;
3) determine borth of the metal detectos as CCP and number them as CCP 1;
In practice: if the metal detectors are placed in series, they will be both checked under the same conditions, because it is hard to explain to your staff that they should be treated different.

[Charles.C]

Dear Madame A.D-tor,

I do agree that the topic is subjective. I guess that’s why HACCP "authorities" have tried to establish a convention.

I found these literature comments helpful in making an opinion –

 CCP vs CP (mortimore).png   219.75KB   33 downloads

 Codex tree, series metal detectors (Surak).png   72.68KB   29 downloads

Two related discussions/posts can also be found here –

http://www.ifsqn.com...dpost__p__34599

http://www.ifsqn.com...dpost__p__35445

Hopefully the OP has validated that both MDs are of equivalent "effectiveness".

There is certainly no unique answer to fit all situations. I would still think the first priority is to avoid excess CCPs (and work?) where not (haccp/auditor) required.

Rgds / Charles.C

[Kellio]

Thank you for all these Information. This will be very helpful for our next Audit. Greatly appretiated!!!!

Dear Madame A.D-tor,


I do agree that the topic is subjective. I guess that’s why HACCP "authorities" have tried to establish a convention.

I found these literature comments helpful in making an opinion –

 CCP vs CP (mortimore).png   219.75KB   33 downloads

 Codex tree, series metal detectors (Surak).png   72.68KB   29 downloads

Two related discussions/posts can also be found here –

http://www.ifsqn.com...dpost__p__34599

http://www.ifsqn.com...dpost__p__35445

Hopefully the OP has validated that both MDs are of equivalent "effectiveness".

There is certainly no unique answer to fit all situations. I would still think the first priority is to avoid excess CCPs (and work?) where not (haccp/auditor) required.

Rgds / Charles.C

[Kellio]

Thank you for all these discussions. I have learned more about CCP's than I thought I would. Thank you!!!

Dear Charles,

I agree with you that in HACCP-studies the latest control measure is normally the CCP. In this case the first metal detector, which is detecting individually bags, is probably more accurate ( I mean can detect smaller pieces) then the second one, which is detecting 6 bags in a case.

But like I wrote before, I believe it actually does not matter if you:
1) determine one of the metal detectors a CCP and the other not;
2) determine both of the metal detectors a CCP and number them as CCP 1 and CCP 2;
3) determine borth of the metal detectos as CCP and number them as CCP 1;
In practice: if the metal detectors are placed in series, they will be both checked under the same conditions, because it is hard to explain to your staff that they should be treated different.

[jetgel]

At our plant, if the CCP depends on the point of the line. If there is one Metal detector at the beginning and one at the end then there will be a CCP1 & CCP2. I guess maybe it depends on the plant's preference in creating more CCPs for food safety purposes. But I do agree with the others to try and keep CCPs at a minimum. Less is more in this case.

[Healthos]

Question?



We are Frozen Vegetable Packaging Plant. I am updateing our HACCP Plan and we always had one CCP which is the Metal detector. Now, we have 2 metal detectors, one for bags and one for cases. Is it fair to say that we have 2 CCP's now? Due to they are located apart in the production line.


Any advise would be greatly appreciated.



Thank you

Well my view is that the first metal detecting point should simply be a control point (CP). The second and final metal detector becomes the CCP. The decision making tree in determining this is quite helpful.