Advise on Hazard Analysis on Skimmed milk powder

Dear all,

I am currently working on Hazard analysis of all raw materials in my company. thus, I have a few questions that I hope someone can guide or enlighten me. thanks in advance!

here it goes,

I consider physical hazard (foreign material) in skimmed milk powder supplied by supplier Y as not a significant hazard. my justification would be

1) supplier's process flow chart indicates that there will be sifting involved before packing and presence of metal detector during packing.

2) no evidence of any historical occurrence from this product in my company

3) supplier's conformance to absent of foreign material in COA (in COA, supplier will state Absent of Foreign Material)

So, is it correct for me to say there is no significant physical hazard. if Yes, are my justifications sufficient to convince my auditor?

look forward to receiving your reply.

help, anybody?

Please be patient Leeling, you will get a reply in due course.

Our moderators will bump a topic if there is no reply within a day or two, so no need for you to do it... especially as you only posted your question a couple of hours ago. :smile:

Hello leeling:

Besides the control measures implemented by supplier Y, do you have any sieving process or metal detector / X-ray machine installed in your company? Did you conduct any supplier audit to the manufacturing site of supplier Y before? Is supplier Y a very reputable one?

You can add these as your measures to further reduce the likelihood of physical contamination.

Yong

Dear Yong,

Yes, we do have a filtration step involved for skimmed milk before they are being pumped into blending tank. I guess I shall add this point to strengthen my justification. No, we haven't conduct any supplier audit at manufacturing site.

On what basis a supplier is considered a reputable one? from what point of view we consider them as reputable?

thank you so much for answering!

look forward to receiving your reply.. :ejut:

First thing I would say is, that no matter how reputable the company, things can and often do go wrong.

Because your getting a COA saying "Foreign Body Free" doesn't mean it will be 100% free of FB.

Even though the supplier has sifting & metal detecting, all that would do is (potentially) detect any metal pieces that may have come from the sieve. Does it mention the gauge of the sieve?

What about fragments of seal (believe me, I've seen SMP with disintegrated seal in it) ? or paper contamination from the sack? what about pieces of string from when the sack is stitched? or (more often than not) clear plastic fragments from the liner?

If you perceive there being no risk, why are you filtering?

I think there is a risk, your assessment should be to calculate how significant that risk potentially is.

Caz

Dear Caz,

Actually I rated this as a "low significant risk" based on Risk Assessment Matrix. However, there is another column in my hazard analysis worksheet whereby it say "Is this a significant hazard? Yes/No" . So my above justifications are meant for this

question which I considered it as No (due to not a significant hazard). What say you?

Thank you. :ejut:

LeeLing

Its your risk assessment  Leeling

If that's how you've rated it, then that's fine.

Caz

Hello leeling:

For me, a reputable supplier (e.g. Murray Goulburn for dairy products) is normally a big company with plenty of food safety measures being implemented (You can do a background check from their websites, their specifications, feedback from other customer etc). I am sure you are not going to buy any ingredient from normal sundry shop or any supplier without implementing any food safety system (no GMP or HACCP certificate), right?

Hazard significance is determined by it's possibility (historical occurence) and the severity of human illness if it's consumed.

You said no evidence of any historical occurrence from this product in my company so the possibility is LOW (not zero because foreign matter also considered as hazard by your supplier)

What if there's a metal fragment eaten by your consumer? Death, gastrointestinal bleeding? so the severity is HIGH

Conclusion : since there's a possibility of foreign matter contamination even low incidence and it may cause fatal impact to human health, you have to consider this hazard as SIGNIFICANT.

On next step you have to answer Decision Tree to decide whether skim milk's receiving step is CCP or not

Here are a few questions for us to ponder:

Are you getting all of the skimmed milk powder from only one company all of the time?  In my last position we used to get powdered milk via a broker so it was a pain to keep up with requesting relevant documentation.  I'm assuming from what you said it's only 1 supplier but I never fully assume anything.

Is your supplier under a GFSI certified food safety standard and/or any other standard?  Yes we all know this isn't something that provides absolute protection... but it helps to analyze risk.

Do you have any type of control point (IE Inspection) for your filter that the skimmed milk powder goes through?  That is if it is defeated by a hole in the filter today will you be aware anytime soon?

Does your supplier have a control point for their sifters?  (if they are under a GFSI standard they should)

Have you reviewed your suppliers HACCP plan? Do they have a HACCP plan?

Have you asked them the last time they had a customer complaint for a foreign material in their product and what their Corrective Action Plan was?  How many times, on average in a year, they have complaints for foreign materials?

For me a reputable supplier is a supplier that at least forwards all relevant documentation, when requested, for their system. Possibly they may be well known and is known for producing a quality product.  Ones that understand why your asking these types of things and do whatever they can, within the constraints of their policies, to give you all appropriate information. Have a full HACCP plan, audited to a well known standard, food defense plan, and all of the other normal good stuff.

Sure they may say no when you ask for something... but it doesn't stop you from asking.

Personally, just from what I've seen above, I'd rate it as a high severity with a low probability with the rational that foreign materials are a danger to health but there are layers of sifting/filtering being done and therefore there is lower risk of it getting through the process.  This would give it a level, off the top of my head and not knowing your HACCP plan, that you can control it with your filter and just have an inspection of your filter.

But that's only if the mesh size of the filters are small enough to remove a foreign body.

That's my opinion on the situation with the current information.

Dear leeling,

IMO, for a commercial product as you mention,  from an auditor's POV you are worrying unduly.

You simply insist on the supplier providing a Product Specification which states that item is Food Grade and the spec. details support such a claim. From an auditor/ HACCP POV, IMEX  this  >> Q.E.D.

Of course if you wish to personally verify such, that is a different story and up to you. Unless you have a specific reason for distrust, IMEX, one believes the spec.

Rgds / Charles.C

PS - if the Company lacks such documents, this is an automatic HACCP NC anyway IMEX. :smile:

PPS - if you wish to see a sample haccp layout, have a look at the worked haccp example for yoghurt on this forum which uses SMP as an ingredient, from memory.

Dear Leeling,

At the supplier level, are they conducting an inspection of the packing material to remove the probability of hazards entry. Further subsequent to their despatch till you open the bags for your production, how do you rate the probability of hazard entry? The severity of the Physical hazard or a Chemical hazard or a Biological hazard in this period is high. If your post operations are taking care of these hazards systematically, then you can consider the risk is medium. You need to have data for this -  more from your lab - sieve analysis result, micro results and organoeleptic evaluation reports of the incoming milk powder.

Krishnan, R

India

Dear all,

Really appreciate all the valuable comments here. As a fresh grad with little experience of HACCP, to come out with a Hazard analysis plan is really a challenging assignment.

My sincere gratitude to all of you here!  :rock:

LeeLing

Good luck :thumbup:

The ket stone is the metal detector during packing