25 replies to this topic

[Jcchaser]

We are in the process of  purchasing a our first metal detector. We will use this in our Grind operation after packaging. We have an issue with metal clips from chubs contaminating product at packaging. We would like to make the metal detector into a pre-requiste. Can anyone tell me why this won't work and if we should make it a CCP instead? Also, what would your recommendations be for documentation steps from Pre-Opeatrion Inspection to calibration and everything in between? 

[Charles.C]

We are in the process of  purchasing a our first metal detector. We will use this in our Grind operation after packaging. We have an issue with metal clips from chubs contaminating product at packaging. We would like to make the metal detector into a pre-requiste. Can anyone tell me why this won't work and if we should make it a CCP instead? Also, what would your recommendations be for documentation steps from Pre-Opeatrion Inspection to calibration and everything in between? 

Hi Jcchaser,

 

Is yr haccp plan intended to be audited for any particular FS standard ?

 

"chubs" is a new word for me.

 

What do you mean by Calibration ? Routine Testing with standard wands during Production ?

[softball332002]

Hi Jcchaser,

 

Do you have historical data on these "chubs" and their sizes when found in the product? What about complaints history concerning foreign material (internal and external complaints)? Also, I would have a strong validation methods; such as challenging the machine with the actual risk (chubs); not just standard test wands. You can make this a into a pre-requisite, but be ready to have some historical data for validation and a thorough risk assessment.

[brianweber]

I am assuming that "chubs" are the plastic sealed ground meats that have the metal clips on the ends of the packaging. It sounds like it is a significant risk so i would lean towards making it a CCP

[Charles.C]

Hi Jcchaser,

 

The previous posts make good Risk Assessment (RA) points.

 

Your OP is conceptually asking as to the permitted scopes of the terminologies PRP and CCP in a HACCP context, eg is there a (RA) borderline between them ?

 

Theoretically the current usage of these terms is highly variable, notably depending on the situation.

 

I suggest that a pragmatic answer might be that it depends on who is going to audit your choice.  First priority is to any regulatory context and secondly a customer/FS Standard.

 

If Yr HACCP Plan is for internal use only,  then in principle you can define your own terms, but in the Grand Scheme of HACCP/ Risk Assessment,  yr decision /results should be logical, validatable, and verifiable (for example as interpreted by Codex) from a FS POV.

 

A little feedback may be  required for more meaningful opinions.

[vstevenson]

I am making our metal detector a CCP also.  How do I go about validating this piece of equipment and what supporting documentation do I need (where to find any)?

[Charles.C]

I am making our metal detector a CCP also.  How do I go about validating this piece of equipment and what supporting documentation do I need (where to find any)?

Hi vstevenson,

 

I assume you mean validating (a) the CCP and (b) the critical limits.

 

(a) is validatable by yr use of an appropriate haccp methodology, eg Codex/NACMCF so as to determine a CCP.

 

(b) is validatable by yr demonstrating that the sensitivity of yr MD is capable of detecting/removing hazardous metallic contaminants.

 

For example see the text detailing the MD step in the haccp plan attached in this post -

 

http://www.ifsqn.com...indpost&p=91553

 

The specific details will relate to yr own Product/Process

[sklar]

Is yr haccp plan intended to be audited for any particular FS standard ?

 

This is a very good question to be asking.

 

In one of my previous roles as HACCP coordinator for a producer of dips and spreads, we had listed our metal detectors as a CCP mostly due to demands from our largest retail customer. Regardless of what our risk assessment said, this customer wanted to see metal detection as a CCP.

[clbernard]

Part of the validation (is the step able to control the hazard) must be documentation from the manufacturer stating what the equipment is capable of finding in your particular product and under your conditions of running, ie drop thru, in the box, etc.

 

I agree with others that more understanding is needed on the situation, but to me it would be particularly interesting to understand the process of what is being ground, as any grinding implies a mixture or blend of product that could easily hide foreign material. If the foreign material could be held and hidden within the final product, making it more difficult for the consumer to detect and thus easier to consume, I would tend to make it a CCP regardless of history of complaints.

 

For verification (is the step being operated according to the plan, are people doing what should be done and is the equipment working as it should) keep a record of the MD tests run with the standards or test devices and any deviations that occur along with the corrective and preventative actions taken.  A simple log sheet with the date, time, lot run, description of the product, along with spaces for time, who is performing the test, the test results (we have always found it helpful to note if the device used to perform the test is intact) and space for comments along with a daily or more frequent review of the testing sign off by a supervisor are typically used.  Common sense requires that the unit be tested prior to start-up (meaning as the first of the product is running thru the MD), at a frequency through out the shift to keep the amount of product to be place on hold at a minimum and at the end of the run as the last of the product is passing through the MD.  The units must always be tested with product as this makes it more difficult to 'find' the metal and provides a real-life scenario for the unit.  Anytime the metal detector fails to detect the test devices it must be assumed that the unit is not functioning and has not been functioning since the last check as no one can tell for certain as to when it stopped functioning after that last check.  Therefore all product since the last check until the unit is fixed and tested to indicate full functionality must be placed on hold and re-ran thru a functioning unit.  It is typical for line operators to doubt the MD and want to just re-run a test card or device when the first pass does not pick up on the metal.  

 

Periodic manufacturer 'tune-ups' along with calibration paperwork will be required and most manufacturers provide this paperwork to begin with a date of expiration.  It is a good idea to find out the name of the local company authorized to perform these calibrations and have them come after installation before first use as sometimes things go wrong during transport or installation.

 

This may be more than what you are asking for, so sorry if I run on a bit.

 

 

Good luck to you, another thought is that if you make it a CCP it is easier to get good compliance with line operators as they 'must' handle it with respect for it's impact on consumer health and well-being.  But of course only you can balance that impact against the regulatory and audit kick-back if handled badly; then again who would want any foreign material to be allowed to go to the consumer.

 

Cheryl 

[CMHeywood]

CCP: this is the last point (or the only point) at which you can detect and control the contamination.

 

Prerequisite:

(1)  you can detect and control the contamination at more than one point in your process, or

(2)  you can detect and control the contamination prior to processing.

[Charles.C]

CCP: this is the last point (or the only point) at which you can detect and control the contamination.

 

Prerequisite:

(1)  you can detect and control the contamination at more than one point in your process, or

(2)  you can detect and control the contamination prior to processing.

 

Thoughtful as usual. Perhaps CCP should have included the word "process".? And "significant" contamination.?

 

But, nowadays, perhaps it's easier to be prescriptive and state that a Prerequisite is "by definition" . Whereas A CCP is by (process) risk assessment.

 

@clbernard - I agree the risk assessment is fundamental. It may also be necessary to differentiate between -

 

"verification" and "monitoring"

 

 "calibration" and "validation"

 

"CCP" and "Prerequisite".

[Kate90]

By definition a CCP is a step who is created for reducing or eliminate a hazard. So i think it should a CCP. 

 

In fact you should monitoring contantly the results of this step. The measurement of the effectiveness of a pre-requisite you can do it monthly. I think in this case you can’t do it with that frequency. 

 

My organization is certified in FSSC 22000. 

[Tony-C]

We are in the process of  purchasing a our first metal detector. We will use this in our Grind operation after packaging. We have an issue with metal clips from chubs contaminating product at packaging. We would like to make the metal detector into a pre-requiste. Can anyone tell me why this won't work and if we should make it a CCP instead? Also, what would your recommendations be for documentation steps from Pre-Opeatrion Inspection to calibration and everything in between? 

 

There is plenty of information on the forums regarding size of foreign body and what constitutes a hazard. Here is a useful bit of background:

http://www.fsis.usda...gnMaterials.pdf

 

With any product the end consumer needs to be considered when assessing the risk.

 

What you are talking about is a specific control measure to control a specific known hazard and therefore to my mind this is as clear a case for metal detection being a CCP as you can find.

 

Commissioning and validation should ensure the metal clips are effectively removed when present in the product.

 

Regards,

 

Tony

[SriramB]

Hi Jcchaser,

 

The previous posts have covered a lot of ground; and purely from  a RA point of view:

 

1.  Assuming that the hazard (e.g.  metal body that can cause choking or laceration), is detected / controlled  by the Metal detector in your process is deemed significant ( ie, is probable and can cause severe issues to consumers).

2.  Assuming this detector is the last point in your process where there is an opportunity for the contaminant to be detected / controlled;

3.  and Finally assuming, this detector is calibrated  to such a sensitivity that it can indeed detect/ control ALL of the  potential metal contaminants; AND, has been Validated ( by challenge tests etc)  to prove that all potential metal contaminants (that are present in your factory  which could potentially find their way into the  product) are detected controlled, 

 

4.  then; you indeed have a very beneficial and effective Point in your process where a Critical Hazard  is Controlled to the Acceptable limits... in this case it would be a CCP.

 

 

If you cannot ; 1. Validate that the detector will guarantee complete detection of the hazards, OR

                        2. You cannot trust it to work continuously in an effective manner ( in summary, if you doubt that, the detector may NOT prevent the metal contaminant from reaching the consumer);

 

       then what you have is an Uncontrolled Hazard ; and a point in the process which may be doing a reasonably good job, but cannot be claimed to be a CCP , that provides complete assurance that the hazard is          eliminated.

 

-----

If your regulations, Customer requirements or general Industry standards mandate that a Metal detector needs to be in place in your industry, then it may well be a prerequisite; but you need to take care that , that unless you can validate its effectiveness, you cannot assume it to be a CCP.

 

Cheers,

 

Sriram

[Tony-C]

3.  and Finally assuming, this detector is calibrated  to such a sensitivity that it can indeed detect/ control ALL of the  potential metal contaminants; AND, has been Validated ( by challenge tests etc)  to prove that all potential metal contaminants (that are present in your factory  which could potentially find their way into the  product) are detected controlled, 

 

 

Cheers,

 

Sriram

 

Not sure anyone validates that a metal detector can remove ALL potential metal contaminants?

 

Regards,

 

Tony

[MWidra]

Hi vstevenson,

 

I assume you mean validating (a) the CCP and (b) the critical limits.

 

(a) is validatable by yr use of an appropriate haccp methodology, eg Codex/NACMCF so as to determine a CCP.

 

(b) is validatable by yr demonstrating that the sensitivity of yr MD is capable of detecting/removing hazardous metallic contaminants.

 

For example see the text detailing the MD step in the haccp plan attached in this post -

 

http://www.ifsqn.com...indpost&p=91553

 

The specific details will relate to yr own Product/Process

I think that he meant that he wanted to know how to qualify the equipment.  Most people get those terms mixed up, it is confusing.  You really need to qualify the equipment used for critical functions, as well as validate that the procedure for using it is capable of performing what you need it to do.

 

Sometimes the equipment manufacturer has pre-qualified the design of their equipment with standard parameters.  They you only have to qualify the installation and the performance of it.  Some will even qualify it for you, for a fee, after it is installed.

 

Martha

[SriramB]

Not sure anyone validates that a metal detector can remove ALL potential metal contaminants?

 

Regards,

 

Tony

 

Agree, Tony..

 

Just been interested to realize that, many a times, a Control Point is classified CCP, even though there is no evidence it can do the job in all eventualities.

 

In my view, if you have a CCP in the process, then you are forgiven to believe, that, if the CCP was fully operational, then you would not expect to find the Hazard in the finished product.

 

Many a times, a Control point does do ( or is designed to do) a very good job, but if you cannot know for sure that all the  Hazard instances are covered, maybe "not" categorizing as a CCP, ( whilst giving the point all the attention it deserves ) may serve the interests of consumer/ stakeholders, by not lulling them into a 'unproven' sense of security.

 

Obviously, that said, in the real world, you do the best you can for the consumer and say the appropriate  words during audits :)

 

Thanks,

Sriram

[Charles.C]

Hi SriRam,

 

The limitations imposed by LOD (or LOQ) are often relevant in a practical situation.

[SriramB]

Very true, Charles. ( previous posts were purely with a academic, 'holier than thou' hat on)

 

To be truthful, I do fall back on technical limitations and /or costs , to justify dependence on some control measures, which from a pure academic point of view, I know, cannot be guaranteed to perform 100% control.   In saying that, they are probably the best mitigation control that is available or , we can afford, at the time!

 

( Indeed, in some  cases, a measure miraculously becomes a CCP , just because a customer or an auditor, might want it so ! Not saying that happens anywhere      )

 

The great thing  with a 'utopian' HACCP exercise is that , once you are aware of a potential shortcoming in your controls ( although you may have a great document readied for audits! :) ), you look forward to technical advances / new information; which in some cases, help you improve the controls  to achieve acceptable limits.

 

Thanks !

 

Cheers,

Sriram

[Tony-C]

Agree, Tony..

 

Just been interested to realize that, many a times, a Control Point is classified CCP, even though there is no evidence it can do the job in all eventualities.

 

In my view, if you have a CCP in the process, then you are forgiven to believe, that, if the CCP was fully operational, then you would not expect to find the Hazard in the finished product.

 

Thanks,

Sriram

 

Hi Sriram,

 

You are talking about all general metal hazards not being removed by the metal detector in all eventualities.

 

There would not be an expectation of that even if it is a CCP, as I said in my previous post:

 

What you are talking about is a specific control measure to control a specific known hazard and therefore to my mind this is as clear a case for metal detection being a CCP as you can find.
 

Regards,

 

Tony
 

[MWidra]

Hi Sriram,

 

You are talking about all general metal hazards not being removed by the metal detector in all eventualities.

 

There would not be an expectation of that even if it is a CCP, as I said in my previous post:

 

What you are talking about is a specific control measure to control a specific known hazard and therefore to my mind this is as clear a case for metal detection being a CCP as you can find.
 

Regards,

 

Tony
 

For everyone following this forum, I hope that people who are saying that metal detectors REMOVE metal really mean that they detect the presence of metal so that it can be rejected.

 

But...this could be misleading to someone who is new to food safety and does not realize it.  Not all metal detectors automatically reject the product, depending on the size and configuration of it. 

 

ONLY a magnet can remove a piece of metal, and only then if it is a magnetic metal.  That being said, you can argue that a metal detector that does NOT automatically reject cannot be a CCP because it does not CONTROL the hazard, only detects it.

 

I think that we assume that everyone here knows this, but you know what they say about what you do if you assume...

 

Thanks for keeping it clear for the newer members.

 

Martha

[Tony-C]

For everyone following this forum, I hope that people who are saying that metal detectors REMOVE metal really mean that they detect the presence of metal so that it can be rejected.

 

But...this could be misleading to someone who is new to food safety and does not realize it.  Not all metal detectors automatically reject the product, depending on the size and configuration of it. 

 

ONLY a magnet can remove a piece of metal, and only then if it is a magnetic metal.  That being said, you can argue that a metal detector that does NOT automatically reject cannot be a CCP because it does not CONTROL the hazard, only detects it.

 

I think that we assume that everyone here knows this, but you know what they say about what you do if you assume...

 

Thanks for keeping it clear for the newer members.

 

Martha

 

Thank you Martha for the clarification, why would you have a metal detector if it didn't remove the hazard in your process?

 

 Guide_to_Metal_Detection.pdf   465.03KB   63 downloads

 

What you are talking about is a specific control measure to control a specific known hazard and therefore to my mind this is as clear a case for metal detection being a CCP as you can find.

 

Commissioning and validation should ensure the metal clips are effectively removed when present in the product.

 

 

Regards,

 

Tony

[MWidra]

Thank you Martha for the clarification, why would you have a metal detector if it didn't remove the hazard in your process?

 

Guide_to_Metal_Detection.pdf

 

Regards,

 

Tony

If your product comes out in 55 lb bags and they don't make metal detectors that can reject something of that size.  If you product comes out in bulk bags that cannot be automatically put into a bin.  Everyone does not make packaged chicken pieces on a tray, lol.

 

it is always a good idea for people to understand the operation of a piece of equipment and know its limitations.  If they don't have an automatic rejection system, then the metal detection needs to have the procedure associated with it to assure that the hazard is removed, even if it is just quarantine.  You can't design or properly utilize a program without knowing what is going on.

 

Martha

[trubertq]

Metal detectors DO NOT REMOVE Metal from product they only DETECT metal and may/may not reject the product wherein the metal is detected. 

 

The metal detector I am familiar with just has a stop belt and alarm and it is up to the operator to remove the carton ( 15 kg) and send it to QC for further investigation.

 

It is calibrated annually and verified hourly.....

[Tony-C]

Hi Sriram,

 

You are talking about all general metal hazards not being removed by the metal detector in all eventualities.

 

There would not be an expectation of that even if it is a CCP, as I said in my previous post:

 

What you are talking about is a specific control measure to control a specific known hazard and therefore to my mind this is as clear a case for metal detection being a CCP as you can find.
 

Regards,

 

Tony
 

 

Specific product, specific control system (with rejection or stop which is a prerequisite for metal detection).

 

If your product comes out in 55 lb bags and they don't make metal detectors that can reject something of that size.  If you product comes out in bulk bags that cannot be automatically put into a bin.  Everyone does not make packaged chicken pieces on a tray, lol.

 

it is always a good idea for people to understand the operation of a piece of equipment and know its limitations.  If they don't have an automatic rejection system, then the metal detection needs to have the procedure associated with it to assure that the hazard is removed, even if it is just quarantine.  You can't design or properly utilize a program without knowing what is going on.

 

Martha

 

LOL in line detection and rejection LOL

 

Regards,

 

Tony