2 replies to this topic

[ganderson64]

The question regarding the possible introduction of foreign material during the process is up in the air.

How are other operations handling the hazard control as required by the hazard analysis of the HACCP?

Say in a batch processing operation with a metal detector toward the end of the process, is there any up-stream redundancy called out to mitigate the potential introduction of foreign materials?

Facilities / Preventive maintenance? Post operation equipment inspection?

Any clarification would be valuable.

[MWidra]

The controls upstream would depend on the product and process.  We have a dry product, and ferrous metal contamination is our major hazard.  We have sifter screens and magnets upstream, but the CCP is the magnet at the final pack-out station.

 

All of the magnets are inspected each shift, but they are not all CCPs and therefore most are not important to HACCP.  HACCP is only interested in the CRITICAL control point that prevents any metal from entering the product.  Since there are moving parts right before the final pack-out station, the magnets that precede the last one don't prevent metal from entering the final product.  Only that final one makes sure it's all out.

 

For glass and brittle plastic foreign materials, we have a prerequisite program that makes sure that those items do not enter the product.  So that hazard is prevented by that program.

 

That is how we handle foreign materials, hope that helps you consider how to analyze your systems.

 

Martha

[KTD]

Dear ganderson64:

 

MWidra's comments are spot on. One additional consideration would be if you are an USDA inspected plant (coming soon to FDA-inspected plants near you). References to any 'prerequisite' programs that you implement to control FM would need to be discussed in your Hazard Analysis, along with historical data. Realize that under USDA, if your historical data indicates that a particular FM is not reasonably likely to occur in your process, then end of process MD can be a prerequisite program, which is held to a lower regulatory standard than a CCP.