8 replies to this topic

[BillC]

Fairly simple product, small line, 1 metal detector, history of metal in product very rare - i.e. might be one nut or bolt getting through in >5years.

Metal detector required by customer and a reasonable thing to have, so a CCP.

Q: does this mean that if the metal detector has a mechanical failure all production stops until a replacement flown - potentially >a week?

Or would others consider it acceptable to validate - based on history - a period of time in which it would be acceptable to to replace metal detection with hourly inspections are done of all equipment for metal loss or damage - and a time limit placed on obtaining repair or replacement of unit, say of not more than two weeks.

Any references also helpful.

Thanks,

[Setanta]

This thread might be helpful.

You may want to look around and see if there is a neighboring business with whom you could share a back up metal detector. I don't think you or your company would want to go through a recall of all the product that potentially was produced without a metal detector.

Regards,
Setanta

http://www.ifsqn.com...h__1#entry57468

Sorry for all the highlighted "Metal" words, I did a search for this thread using metal as my key word.

Edited by Setanta, 19 March 2013 - 08:40 PM.

[Charles.C]

Fairly simple product, small line, 1 metal detector, history of metal in product very rare - i.e. might be one nut or bolt getting through in >5years.

Metal detector required by customer and a reasonable thing to have, so a CCP.

Q: does this mean that if the metal detector has a mechanical failure all production stops until a replacement flown - potentially >a week?

Or would others consider it acceptable to validate - based on history - a period of time in which it would be acceptable to to replace metal detection with hourly inspections are done of all equipment for metal loss or damage - and a time limit placed on obtaining repair or replacement of unit, say of not more than two weeks.

Any references also helpful.

Thanks,

Dear BillC,

What does the Corrective Action in yr HACCP plan say ? The typical text involves stopping production where an in-line Critical Limit is totally failed or un-monitorable, eg due equipment malfunction. After all it's a logical decision based on yr own risk assessment.

My sympathies, it's a classic nightmare scenario unfortunately. Usually involving instant confrontation with Production. The previous post is usually first avenue to explore. My experience is to acquire / preserve some decrepit but still functional back-up as a last line of (evidential) defence.

Yr query regarding revalidation of the HACCP plan based on appropriate verification activities is conceivable but that would typically be to remove the MD altogether.

Rgds / Charles.C

[john123]

I too am curious what your current corrective actions states. I can't think of any scenario that would allow you to bypass a CCP for convenience or because it quit working. You might consider finding a company with a technician qualified to work on that equipment locally, so you can call someone the minute it fails to minimize your downtime.

[BillC]

I too am curious what your current corrective actions states. I can't think of any scenario that would allow you to bypass a CCP for convenience or because it quit working. You might consider finding a company with a technician qualified to work on that equipment locally, so you can call someone the minute it fails to minimize your downtime.

The current corrective action states must stop production; so the question really was - can I change the wording of the CA? Sounds like no is the answer. Logic becomes a Catch-22; if you have a metal detector, it's a CCP, if it's a CCP you have to have a metal detector at all times.

Looks like the best solution is the one above on sourcing a second, possibly decrepit, metal detector as a back up.

Thanks for the input guys.

Bill C.

[john123]

I agree with your logic there, and believe me it's no easy task to stop production when a problem like this arises. Keep in mind that any replacement MD must meet the same criteria established in your HACCP. If you find a "decrepit" MD to keep as a backup, it should be able to meet the same critical limits of the one it is replacing.

[Marshenko]

The current corrective action states must stop production; so the question really was - can I change the wording of the CA? Sounds like no is the answer. Logic becomes a Catch-22; if you have a metal detector, it's a CCP, if it's a CCP you have to have a metal detector at all times.

Looks like the best solution is the one above on sourcing a second, possibly decrepit, metal detector as a back up.

Thanks for the input guys.

Bill C.

My metal detector isn't a CCP, but that's a whole other thread

[George @ Safefood 360°]

Some retailer standards will demand you have a No Detector - No Production policy in place regardless of whether it is a CCP or not.

This may not have been a solution in your case but one thing that may work (and i have seen it done) is to keep producing the product and then quarantine it. When the detector is fixed and when the metal detection unit is available put all the quarantined product through the unit and pass it as normal. Needless to say this depends on many factors, the product shelf life for one. Specification may call for all product to be metal detected. It may not say at the time of production.

Work out the cost of this mechanical failure to the company. Then work out the cost of maintaining a stock of critical spare parts. Also as previously posted a local guy who can conduct repair at short notice would be very valuable.

George

[moskito]

Hi BillC,

the arguments are already in the threat - if you have a MD this is a CCP. We have a back up MD in each plant. These are normally used for reexamination of packs thrown out and can be used in extraordinary situation until a technican is available. We have fixed response time in contracts for service availability.

If you don't have/need a MD, you have to argue very carefully. From BRC is a decision tree available for MD (see homepage).

Rgds

moskito

Fairly simple product, small line, 1 metal detector, history of metal in product very rare - i.e. might be one nut or bolt getting through in >5years.

Metal detector required by customer and a reasonable thing to have, so a CCP.

Q: does this mean that if the metal detector has a mechanical failure all production stops until a replacement flown - potentially >a week?

Or would others consider it acceptable to validate - based on history - a period of time in which it would be acceptable to to replace metal detection with hourly inspections are done of all equipment for metal loss or damage - and a time limit placed on obtaining repair or replacement of unit, say of not more than two weeks.

Any references also helpful.

Thanks,