Hi Jeff
I would say that Metal Detection would need to be a CCP. It is you last line in defense for detecting metal contamination. Although you've hisorically not had any complaints, you can bet your bottom dollar, the day you downgrade it, you will!
Both checks / set up are carried out by either a QA or a operator, who veify each others work, where i'm at. The verification in fairness is just to check their on correct product, correct test pieces etc. so more of a cursory glance than a heck, but it is documented.
Question 3 is really interesting. The frequency of checks is to verify that the MD is still working. The only difference for you would be that if the end check failed, then you'd have to ut the whole batch or run on hold , and recheck, rather than an hours worth. So if your management are in agreement and you can segregate that amount of product, then why not. You cold introduce a "random" check per run. If i was auditing you, and you had that documented, then i can't see how i could give you a NC. Maybe someone else has a different perspective.
Caz x
I agree with your idea on #3 here, although I would add that I would first have some documented data to support a move to less frequent checks... e.g. not only do you not have a history of
metal contamination, but we have 6 months worth of checking the
metal detector every hour with this set of standards, never had a deviation, therefore we feel that checking it twice per shift is acceptable. I wouldn't do it personally, because like Caz says, if you do have an issue where the
metal detector is found to be out of calibration, it would create a lot more work for your team having to them go back, find all the affected product, re-check it, etc.
#2 - As long as your operators are properly trained (and the training is documented), there's no reason they can't run the
metal detector wands through at whatever frequency you decide. Its not rocket science, just make sure that they know to:
a. Run all the wands with product
b. Re-run the product that you used when you sent the wands through for verification to ensure that they don't actually contain metal
c. Know what to do in the event that the
metal detector doesn't detect one of the wands
d. How to document their findings
As far as whether or not
metal detection should be a
CCP... I'm going to shut my mouth. I've never had it as a
CCP in any of my
HACCP plans