Making an X-Ray a control point, not a critical control point.
I am updating our HACCP and would like to make X-Ray a control point, not a critical control point. The product is a potato which we wrap for baking.
The justification I have for the X-ray step not being a CCP:
Monitoring POTATOES ARE VISUALLY INSPECTED AT INSPECTION STEP WHERE ANY VISIBLE FOREIGN OBJECTS ARE DISCARDED, X-RAY IN LINE, PRODUCT NOT RTE
Corrective Action X-RAY RECALIBRATED IF CARDS ARE NOT REJECTED, IF X-RAY IS OUT OF LINE FOR SERVICING, CUSTOMER IS NOTIFIED THAT POTATOES ARE NOT BEING X-RAY DETECTED - (X-RAY DETECTION IS NOT A CUSTOMER SPECIFICATION), PRODUCT IS NOT RTE, CUSTOMER PREPARATION INCLUDES HANDLING, VISUAL INSPECTION AND COOKING
Is this acceptable?
I am updating our HACCP and would like to make X-Ray a control point, not a critical control point. The product is a potato which we wrap for baking.
The justification I have for the X-ray step not being a CCP:
Monitoring POTATOES ARE VISUALLY INSPECTED AT INSPECTION STEP WHERE ANY VISIBLE FOREIGN OBJECTS ARE DISCARDED, X-RAY IN LINE, PRODUCT NOT RTE
Corrective Action X-RAY RECALIBRATED IF CARDS ARE NOT REJECTED, IF X-RAY IS OUT OF LINE FOR SERVICING, CUSTOMER IS NOTIFIED THAT POTATOES ARE NOT BEING X-RAY DETECTED - (X-RAY DETECTION IS NOT A CUSTOMER SPECIFICATION), PRODUCT IS NOT RTE, CUSTOMER PREPARATION INCLUDES HANDLING, VISUAL INSPECTION AND COOKING
Is this acceptable?
Hi TLopez,
Thanks for yr Query and Welcome to the Forum ! :welcome:
I assume the x-ray unit is scanning the finished product.
I assume you are asking from a HACCP-audit POV ?
I'm unclear what the auditable requirements of a CP are ? (It may depend on the auditor, eg BRC, ISO ?)
Some users automatically set MD/X-Ray as a CCP to avoid auditor debates. And occasionally because need at least one CCP.
Overall it's a Risk Assessment / Control question, ie whether, from the consumer's POV, the existing hazard control(s) is adequate to not designate X-ray as a CCP ? (possibly including further upstream controls if validatable.)
Some people set as PRP based on a risk assessment, eg see the attachment in this post (also includes a CCP plan for MD/X-ray) -
http://www.ifsqn.com...ill/#entry83137
Alternatively the X-ray detector might be regarded as a verification mechanism for the preceding foreign body removal stage(s), eg see this Codex document, Pg14 -
Codex 2008 validation of FS control measures.pdf 206.71KB 86 downloads
For a CCP/PRP, yr capitalized corrective action is not very meaningful IMO
Hi TLopez
Having worked in potato processing previously, I would suggest X-ray to be a CCP - and would also suggest it is an advancement on the metal detection of potatoes!
Potatoes have an unfortunate habit of growing around objects in the soil - so one would reasonably expect 'natural' foreign bodies (stones in particular) to be common within the potatoes. (does your consumer complaints data suggest this?)
Therefore, X-ray of potatoes could be a process step which reduces this hazard to an acceptable level and is a step specifically designed to do so. It may also be a process step which is applied to ALL finished items (as CCPs effectively are)
Stuart
Hi TLopez -
As mentioned by Charles, the decison should come from both your Risk Assessment for your facility and your knowledge of similar FM food safety risks experienced by other suppliers.
To add to StuartMarriot's comments, several years I was involved in a rash of 'glass' complaints in prepared meals featuring sliced or diced potatoes. Our investigation of the supplier identified that they had added new production land containing a higher concentration of volcanic soil. When the potatoes were moved from storage, they could be dropped several feet into the trailer. This was allowing tiny clear mineral quartz and related minerals to be pounded into the potato just under the skin. These inclusions were not visible to the naked eye...
KTD