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.
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.