9 replies to this topic

[Oldairyman]

I have a few questions to ask .1. Is your metal detector always assumed to be a CCP or can it be under the HACCP - Pre-requisite program ? #2 Can Operators do the frequent MD ,function checks as part of your HACCP plan or is this a function of your QC/QA dept? Sorry for the 3rd question but since the metal detectors have not failed, atleast at our plant,... and no history of consumer complaints with metal , could one reduce the metal detector frequency checks to beginning and end of run/ lot lot# vs hourly checks as most food plant operations ? (of coarse this under the direction of the HACCP committee)
Thanks Jeff

[cazyncymru]

I have a few questions to ask .1. Is your metal detector always assumed to be a CCP or can it be under the HACCP - Pre-requisite program ? #2 Can Operators do the frequent MD ,function checks as part of your HACCP plan or is this a function of your QC/QA dept? Sorry for the 3rd question but since the metal detectors have not failed, atleast at our plant,... and no history of consumer complaints with metal , could one reduce the metal detector frequency checks to beginning and end of run/ lot lot# vs hourly checks as most food plant operations ? (of coarse this under the direction of the HACCP committee)
Thanks Jeff

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

[Simon]

Check out what members think in this long running poll: Metal Detection - is it a Monitoring Activity or a CCP?

Also 11 pages of comments if you have time.

Hope it can help you.

Regards,
Simon

[Marshenko]

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

Edited by Marshenko, 12 April 2013 - 11:44 AM.

[jenky]

Good questions ... ones that we have debated within our facility, too. Here's my 2 cents:


#1 - CCP or Not. In my experience, some regulatory agencies are more prescriptive than others about what control measures should be a CCP. I have one HACCP plan that has metal detection as a CCP and another plan that does not. So, you might need to take that into consideration. Yes, I know that HACCP decisions are supposed made by the HACCP team, but we all know that in reality some times that is not always that case.

#2 - Can Operators do MD checks? Absolutely! Just make sure they are trained to do them (and document that training). Make operators part of your HACCP team since they are part of the front line. They often have great insight into issues that QA and managers might not.

#3 - Reduce frequency of checks. I would agree with the other posters here that you would need to have some evidence supporting the reduction in frequency, but caution you to take a look at your production cycle. If your production run is 8 hours, rather than cutting your frequency to beginning and end. maybe compromise at a check every 2 hours or every 4 hours and avoid a lot of work rechecking the whole run.

[Charles.C]

I have a few questions to ask .1. Is your metal detector always assumed to be a CCP or can it be under the HACCP - Pre-requisite program ? #2 Can Operators do the frequent MD ,function checks as part of your HACCP plan or is this a function of your QC/QA dept? Sorry for the 3rd question but since the metal detectors have not failed, atleast at our plant,... and no history of consumer complaints with metal , could one reduce the metal detector frequency checks to beginning and end of run/ lot lot# vs hourly checks as most food plant operations ? (of coarse this under the direction of the HACCP committee)
Thanks Jeff

Dear Oldairyman,

1. CCP (as per vast majority IMEX); seen also - rarely, PRP (customer requirement); once, Verification tool (Codex); occasionally, outside HACCP (Books - non-final one of a series of MDs).
2. Yes, if they are also competent to satisfy ancillary auditor's questions, eg regarding corrective actions. So generally No.
3. Some customers (and maybe some Standards) specify a minimum frequency. Otherwise as prev. comments. Can almost guarantee that if you reduce the frequency, will shortly get a calibration failure at end of run.

Rgds / Charles.C

[mgourley]

I guess it all boils down to this: Do you have a metal detector in place to eliminate or reduce contamination of the product by metal to an acceptable level?
If so, it's a CCP, by Codex definition.

If you have a metal detector in place to eliminate or reduce contamination of the product by foreign material to an acceptable level, then it's, IMHO, NOT a CCP.
Plenty of other contamination can pass through a metal detector.
If it's there to specifically detect metal, CCP. If not there to specifically detect metal. not a CCP.
Of course, if you have any chance of metal to metal contact in your process.. or there is any possibility of metal being introduced in your process, (which you would have identified in your hazard analysis) then it's going to be a CCP.

Marshall

[wijit]

Just to add another situation here. We have two metal detectors on one line here. The last is a CCP, however the one we have at a slightly earlier point is a CP until we go onto bulk product. Then it becomes a CCP as that is the last metal detector prior to packing.

Edited by wijit, 17 April 2013 - 01:18 PM.

[Mark B]

In most cases metal detection is a CCP. It should be the last step in the packaging process. I would strongly caution you against getting away from the hourly metal detection checks. I something fails in the metal detection process, and you do not check it until the end of the shift, you now have to hold an entire day worth of production. Hourly checks are the verification for your CCP. Hope this helps

[Shyguy77]

I have a few questions to ask .1. Is your metal detector always assumed to be a CCP or can it be under the HACCP - Pre-requisite program ? #2 Can Operators do the frequent MD ,function checks as part of your HACCP plan or is this a function of your QC/QA dept? Sorry for the 3rd question but since the metal detectors have not failed, atleast at our plant,... and no history of consumer complaints with metal , could one reduce the metal detector frequency checks to beginning and end of run/ lot lot# vs hourly checks as most food plant operations ? (of coarse this under the direction of the HACCP committee)
Thanks Jeff

Sounds like you have a good plan and im in agreement with the other comments on this thread, ill give you a little bit of my advice/experience also.

1. If the metal detection is your last line of defense then yes its a CCP

2. Can operators do the checks -OFC. We have always had the operator running the MD do the verification checks, although we did have a QA person doing an independant check twice a shift.

3. As for lowering your frequency of testing, i would advise not to. Like others have said this is when, what you think won't happen will and if something does happen, now you have alot more to hold and rework.






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