17 replies to this topic

[paconmatt]

I work for a company that makes extruded net that is considered food contact packaging.  We have determined that the likelyhood of metal fragment contamination is almost zero.  Do we still have to install some type of metal detecting device.  (This can be extremely costly for us).  Can we fall back on traceability stating that if there was contamination it would be deliberate, and in that instance trace that particular case back to that employee?

Edited by Charles.C, 03 May 2014 - 06:45 AM.
prefix added to title

[Dharmadi Sadeli Putra]

IMO, since you have determined (without any doubt) that the possibility of metal contamination is almost zero, it's not necessary to install MD. Has your facility been inspected by FDA and any finding regarding metal inclusion?

[Charles.C]

Dear paconmatt,

 

If the decision/consequences within the context of yr overall FS system are only for yr own subsequent interest and will not be required to be produced/justified for other eyes I guess you are not obliged to do anything.

 

Usually the above  is not the case of course. For example, if an auditory objective, it comes down to yr  "nearly zero" risk assessment being validatable from an auditors/standard POV. The latter may depend on product/process/standard/legislation/etc.

 

Rgds / Charles.C

[DP2006]

Paconmatt,

 

Whilst I fully understand your comment on the cost of metal detection, MD is your last control point regarding control of metal foreign bodies.

 

Depending on your company's attitude to risk, ask the question .... what if we have a failure in other systems we use to reduce the risk of metal contamination and we don't have MD as a final defense mechanism ?

 

Is the cost of not having a metal detector worth the risk to our business (brand equity, product recalls, loss of image, loss of confidence etc)?

 

I know this does not address your question from a regulatory / food safety management viewpoint but don't forget about the potential impact of a failure on your business position!

 

Good Luck!

DP2006

[cazyncymru]

I had 1 metal complaint in nearly 28 million units packed. To me, although it works out "nearly zero" CPMU , it's not zero and I want it to be zero, so I will continue to metal detect as a CCP

 

As long as you can justify it. And the auditor agrees or understands your rationale

 

It would be interesting if you posted your justification on here, as I think there are a number of people on here who would like to remove metal detection as a CCP.

 

Caz x

[paconmatt]

I completely agree. But the problem is getting management to understand this.

[paconmatt]

Caz x,

 

I guess I have no true justification of why we feel the possibility of metal contamination is zero.  My arguement (although not good in an inspectors eyes) is that since we manufacture an extruded net there is little chance for fragments to get into our product.  We have magnets in the hopper of the extruder to catch screws etc. but this is so we don't mess up dies.  And we also have screens past the point where the magnets are.  But again this is to protect our machines.  (Wow, I just realized we do have some metal fragment prevention in place).  But what i was worried about is where our label meets our extruded net.  At this process the likely hood is close to zero but I was thinking about using a metal detecting wand on the entire pallet before the pallet leaves the production zone.  Do you think this idea would "fly" in the eyes of the AIB inspector.

 

 

 

 

[Snookie]

As someone who started in food and always had metal detectors and is now in packaging and we don't have metal detectors, have to confess to feeling a bit naked.  However, while we have a metal environment the very nature of our processes and products is that any loose metal is going to cause damage to the product in some way  and make it unusable and will not survive to the end process.  This has been validated by several auditors.  It still feels strange not to have a metal detector. 

[Charles.C]

Dear Snookie,
 

 

This has been validated by several auditors

 

 

It's not my area but yr comment is interesting inasmuch as several other recent posters obviously do use metal detectors.

 

So are there any obvious packaging processes/equipment where the risk is accepted as significant in comparison to others having the opposite assumption.?

 

I am (mentally) comparing the situation to a USFDA text on seafood processing hazards which (briefly) classifies some typical units, eg sieves, conveyors as to whether they will be haccp regarded as a significant risk or otherwise.

 

(I think FDA is the only time I have seen such a generic attempt at categorisation in the food sector.)

 

Rgds / Charles.C

[cazyncymru]

So, are the magnets and the sieves (meshes) CCP's?

 

What happens if the sieve breaks? how do you manage that?

 

Cazx

[campbell]

If using an extruder you need to ensure yourself yhat metal fragments cannot get through the ofirace.  The issue is really about filtration before extrusion and then stoppoing contamination occuring before pacxking.  What size paricles will get through the extruder aqnbd what type of metal detector will then find & remove them?

[Snookie]

Dear Snookie,
 

 

It's not my area but yr comment is interesting inasmuch as several other recent posters obviously do use metal detectors.

 

So are there any obvious packaging processes/equipment where the risk is accepted as significant in comparison to others having the opposite assumption.?

 

I am (mentally) comparing the situation to a USFDA text on seafood processing hazards which (briefly) classifies some typical units, eg sieves, conveyors as to whether they will be haccp regarded as a significant risk or otherwise.

 

(I think FDA is the only time I have seen such a generic attempt at categorisation in the food sector.)

 

Rgds / Charles.C

 

 

Think it all comes down to process.  Sadly there is not the time or space to detail it here and it is a proprietary process as well, but literally any metal intrusion makes the product unusable and clearly evident immediately.  We have some very large notable customers and recognized auditors review our processes and there have not been any requests for or any concerns about not having a metal detector. 

Edited by Snookie, 02 May 2014 - 03:41 PM.

[mgourley]

Without any knowledge of your process I will make a blanket statement.

Food Contact Packaging = Need For Metal Detection.

 

If I were buying your product for use on MY finished goods, that have my companies name on them, metal detection would be a requirement for you to be an approved supplier.

 

Marshall

[Dharmadi Sadeli Putra]

Here is a good ref about metal inclusion and how to develop control strategy

http://www.fda.gov/d...n/UCM252440.pdf

Hope it would be useful for all of us

Rgds

Avila

[Charles.C]

Dear paconmatt,

 

After my earlier post #9, I did a little more digging.

 

With respect to packaging, you may find this post and thread of some immediate interest -

 

http://www.ifsqn.com...ccp/#entry59034

 

Rgds / Charles.C

 

PS - Not necessarily disagreeing with post #13, but perhaps it does sometimes depend on the process/receiver/XYZ.

[fgjuadi]

Um, yeah, you need a metal detector, even if you have magnets at the hoppers.  What if the screw starts scraping the barrels? There's just so many points where misalignment can and does cause metal to metal contact in extrusion. Do you have it aligned by Buhler & Clextral, maintenance, or your operators? Probably operators.  Jesus, there's so many variables and possible contamination points for tiny flakes!

 

Anyway, I'd put the magnets post extrusion and a metal detector at packaging as well. 

If management doesn't agree with your assessment, you have three choices, with 1 and 3 being essentially the same. 

 

1. Let your boss know she hired you because you're an expert in food safety and this is the text book worst contaminant to have (other than used sanitary napkins), and you won't release product until it's safe for human consumption.  You are the best person to decide if this will get you a metal detector or if this will get you fired.

 

2. Write up a proposal / capital expense request laying out the costs of purchasing, maintaining, and running the metal detector (include maintenance,installation downtime & modifications, production hours cleaning etc needed).  Then compare that to the cost of a metal flake recall involving the FDA, their business reputation, and maybe this ->   http://www.bloomberg...monella-1-.html.  Does your board of directors really want to be charged with a federal crime for knowing metal contamination was possible and doing nothing?  Morally, do they/you want to be responsible for injuring someone?

 

3. If you have some experience under your belt, save "starting  over money" for a couple months and quit.  QA jobs are crazy open in the US right now!  I quit a morally bankrupt company where the boss ignored food safety issues - and had my pick of factories to join! You qualify for unemployment if you quit due to safety concerns, your company might give severance packages. Potential jobs  will fly you out and tour you around and give you lunch, then pay relocation fees.  It's kind of fun.  And you get the luxury of working at a place that has the same food safety culture you're looking for. If you're willing to move, it's the best choice you'll ever make.  You don't even have to quit, you can just starting looking. You can work as a consultant, or for an auditing firm.  Now I work at a factory where everyone is happy and we make chocolate.  My boss respects me.  There are challenges, but they are challenges I choose.  Quit, dude.  Let their cheap asses blame FS issues they were too irresponsible to fix on some other sucker who wants to die at the age of 45 from a stress induced heart attack. It's the best idea ever.

 

I recently had a visit from the FDA, and although we have a metal detector that is a CCP, they suggested boosting our daily inline magnet /sieve check from not even in the HACCP plan to a CP.  Their visit was actually super productive and helpful. 

Edited by magenta_majors, 04 May 2014 - 07:07 PM.

[Charles.C]

Dear All,

 

There seems to be a definite split as far as answering the original OP is concerned. Reminds me of the (continuing) MD chronology for food processes. Initially they were highly resisted and probably still are by many small, standalone processors.

 

How much of the split is due to validatable risk assessment / cost / (local) regulatory requirements / "management" / pure subjectiveness is unclear to myself (not in packaging arena).

 

@ magenta_m

 

recently had a visit from the FDA, and although we have a metal detector that is a CCP, they suggested boosting our daily inline magnet /sieve check from not even in the HACCP plan to a CP.  Their visit was actually super productive and helpful.

 

 

Curious advice since CPs are normally excluded from a HACCP plan. Unless this is a USFDA (HACCP) Packaging Perversity.

 

Rgds / Charles.C

[Barrie@RJT]

I have already replied to another post regarding metal detection, but I don't know how to link to it!

 

In short, in our situation as a meat processor we regard the metal detector as an Operational Prerequisite rather than a CCP, as it cannot be regarded a CCP if it is not able to detect less than the test sticks we use.  For instance, it would not detect a single missing chainmail link or a saw tooth, so we have other arguably more effective knife/blade/saw/chainmail checks in place.  Metal detection is just one of our OPRPs to control metal getting into the product.