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Does our x-ray equipment need to be a CCP?


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Jim E.

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Posted 02 November 2015 - 04:07 PM

Folk:

 

The question has been brought to me about the future installation of x-ray equipment on one of our packaging lines.  Does it have to be a CCP if there is a metal detector on the line already?  This is being installed to satisfy one customer demand.  It is a formed poato product and they occasionally find small stones in the product.  Of course this is a regular occurence with material grown in the ground.  We have other equipment along the flow to help remove such material but some will occasionaly get by. We our being advised by our corporate people that no it does not have to be a CCP, but I question that view.  As much as I would like to not have to add an additional CCP, I would like the the forum to give me thier thoughts.  I am not even sure if we will use it except for this one customer once installed.

 

Thanks

Jim



Charles.C

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Posted 02 November 2015 - 05:27 PM

Folk:

 

The question has been brought to me about the future installation of x-ray equipment on one of our packaging lines.  Does it have to be a CCP if there is a metal detector on the line already?  This is being installed to satisfy one customer demand.  It is a formed poato product and they occasionally find small stones in the product.  Of course this is a regular occurence with material grown in the ground.  We have other equipment along the flow to help remove such material but some will occasionaly get by. We our being advised by our corporate people that no it does not have to be a CCP, but I question that view.  As much as I would like to not have to add an additional CCP, I would like the the forum to give me thier thoughts.  I am not even sure if we will use it except for this one customer once installed.

 

Thanks

Jim

 

Hi Jim,

 

I assume the likelihood, severity are both M.

I assume the unit is capable of reducing the hazard to an acceptable level.

i assume no subsequent equivalent control step.

 

If yr risk matrix considered  MM to be a significant hazard, then X-ray stage >> CCP.

 

Unless you prefer to (initially) make it a PRP.


Kind Regards,

 

Charles.C


Jim E.

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Posted 02 December 2015 - 11:04 PM

Further to thsi topic, just finished a CFIA FSEP inspection, Canadians will know what I am talking about.  Anyways the topic comes up in discussion and it is mentioned by our inspector of a new prerequiste program in the CFIA system for foreign material removal equipment and we can place the x-ray equipment under that and not have it as a CCP.  Further, is the fact that we can also place our metal detector under this program and remove it as a CCP as well.  Now that being said we must jump through many hoops to satisfy CFIA for our reasoning to remove the CCP's before we get approval (not sure if I want that fight right now).  But I wonder what GFSI would say about no CCP's?   We would still conduct the same monitoring, verification and validation as we do now but there just would not be the designation of a CCP.

 

                    Thoughts? :rock:



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Posted 03 December 2015 - 02:06 AM

Further to thsi topic, just finished a CFIA FSEP inspection, Canadians will know what I am talking about.  Anyways the topic comes up in discussion and it is mentioned by our inspector of a new prerequiste program in the CFIA system for foreign material removal equipment and we can place the x-ray equipment under that and not have it as a CCP.  Further, is the fact that we can also place our metal detector under this program and remove it as a CCP as well.  Now that being said we must jump through many hoops to satisfy CFIA for our reasoning to remove the CCP's before we get approval (not sure if I want that fight right now).  But I wonder what GFSI would say about no CCP's?   We would still conduct the same monitoring, verification and validation as we do now but there just would not be the designation of a CCP.

 

                    Thoughts? :rock:

 

Hi Jim,

 

I deduce you are you saying that cfia require the same procedures/documentation for PRPs as per CCPs ? Seems unlikely, eg PRPs rarely have critical limits.

 

But if the workload really is the same, appears nothing to gain by changing ?

 

GFSIs presentation of HACCP Requirements uses 6 Tables depending on Product Type/Category (14 Codes).  Codex, NACMCF, Hazard Management System, etc  are variously mentioned. "CCP" per se is nowhere mentioned.


Kind Regards,

 

Charles.C


IzzyP

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Posted 03 December 2015 - 02:14 PM

Jim

 

You've answered your own question

 

The X Ray Machine is being used to look for small stones. Will the metal detector pick these stones up?? So yes, i would say its a CCP, but thats only my opinion. i'm sure others will disagree.



trubertq

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Posted 03 December 2015 - 02:35 PM

I would have thought it was a too in as much as if it failed you could cause serious injury. There is no issue with having no CCPs providing you can show a robust risk assessment which lead to this conclusion.


I'm entitled to my opinion, even a stopped clock is right twice a day

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Posted 03 May 2016 - 12:56 PM

Folk:

 

The question has been brought to me about the future installation of x-ray equipment on one of our packaging lines.  Does it have to be a CCP if there is a metal detector on the line already?  This is being installed to satisfy one customer demand.  It is a formed poato product and they occasionally find small stones in the product.  Of course this is a regular occurence with material grown in the ground.  We have other equipment along the flow to help remove such material but some will occasionaly get by. We our being advised by our corporate people that no it does not have to be a CCP, but I question that view.  As much as I would like to not have to add an additional CCP, I would like the the forum to give me thier thoughts.  I am not even sure if we will use it except for this one customer once installed.

 

Thanks

Jim

Jim

For defining the proper CCPs and thus for achieving a safe HAACP concept the potential hazards in the production process must first be identified by way of a hazard analysis, In a hazard analysis all the physical, chemical, and biological hazards that might possibly occur must be identified.  Physical hazards for example include the contamination of the product with metals, glass splinters, bones, stones, etc.  

A risk assessment also must be performed, analyzing on the one hand the probability of contamination, and on the other hand the effects of such contamination. Also review your Consumer complaints. Do you get a great deal of stone complaints? Does your customer prefer the X-ray to be a CCP? Summarizing, the following questions should thus be answered in the hazard analysis:

- What kinds of contamination may occur during production?

- What is the probability of occurrence of these contaminations?

- What are the possible consequences of these contaminations?
 

I have worked in plants where we had metal detections that were not CCP's because the customer (We were co-packers) did require it to be CCP. I worked in plant where metal detectors and X-rays were both CCP's. In other words, it all depends on your Hazard analysis and risk assessment. Also review your customer complaints.

 

Regards,

Donnell






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