What metal size can the special risk group (infants, surgery patients and the elderly) tolerate? Regulation says that "The Board found that foreign objects that are less than 7 mm, maximum dimension, rarely cause trauma or serious injury except in special risk groups such as infants, surgery patients, and the elderly". Does it mean that even metal dust is not allowed for this special risk group? I need this info since we are applying for HACCP certification. Regulation says that less than 7 mm is allowed as long as we state in our "Sensitive Population" - not suitable for special risk group, but I would not like to do that since I will be stating "For general consumption". Our product is ready-to-eat snack foods.
Pls. help. Thanks
A specific, generally applicable, answer to the question for a lower rejection limit in the OP probably does not exist. A general lower (rejection) answer to yr query based on US approach might be <7mm (see text in the link / example below).
The question is not semantically unreasonable but any answer could depend on many factors, eg legislation, operational factors (food matrix, actual situation, etc) and especially as to the interpretation of the word “acceptable”.
Referring to metal contamination of food, here are a few typical examples of interpretations of “acceptable” which can be found in the literature (various others exist) –
(a) Local legislation requires an absence of metal concentration in food products.
(This obviously requires a further definition / interpretation of “absence” which might come via the options given below, or other literature refs, or self-defined (?)).
(b) the food product shall not contain any metallic contamination which is detected by a metal detector. (This obviously requires a further statement as to the detection level capabilities of the metal detector for a particular food matrix, or as is often the [HACCP] case, ability to detect / reject a standard sized / configuration reference “sample” of one or more types of metal).
(c) The food product shall not be “adulterated”.
This terminology in USA as applied to metal contamination is summarized in a well-known document –
As you probably know, above is based on a previous US “incident” study and contains a summary of USFDA interpretations / guidelines which are apparently used for initiating legal action. No specific lower action limit is given for “vulnerable” groups (and AFAIK never subsequently elaborated by USFDA in print). Other countries have adopted their own terminologies / action criteria / categories, eg a maximum size limit of 2mm is apparently in legislatory use in Belgium within their category system.
(d) An example of a general response to the semantic aspect of the problem is this ISO22004 quote -
Hazard identification and determination of acceptable levels
Where statutory and regulatory authorities have established maximum limits, objectives, targets or end product and/or process criteria for a specific hazard/product combination, the hazard in question automatically becomes relevant for that product.
The “acceptable level” means the level of a particular hazard in the end product of the organization that is needed at the next step in the food chain to ensure food safety; it refers to the acceptable level in foods for direct consumption only when the next step is actual consumption. The acceptable level in the end product should be determined through information obtained from one or more of the sources below:
a) objectives, targets or end product criteria established by statutory and regulatory authorities in the country of sale;
b) specifications or other information communicated by the organization constituting the subsequent step in the food chain (often the customer), in particular for end products intended for further processing or use other than direct consumption;
c) the maximum levels found acceptable by the food safety team, taking into account acceptable levels agreed on with the customer and/or established by law and, in the absence thereof, through scientific literature and professional experience.
So any particular HACCP study typically has to make its own “action” decision / critical limits based on factors like above / available choices (possibly local driven).
Here is a US (HACCP) document which compares some possible action criteria where a metal detector may / (may not be) in use.
Fishery Hazards and Control Guidance 2011.pdf 4.34MB
(See Ch20, Pg 385)
Rgds / Charles.C