18 replies to this topic

[dell]

Hello everyone

In a small food establishment such as a bakery making cake and chocolate... is metal detector a CCP? or not?

is it compulsory to use metal detector in such food activity?


many thanks?

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[ajahmoh]

It is a CCP if there is no further process to reduce or eliminate the hazard which is metal.

 

If you have any alternative to ensure that the cake you produce is not contaminated with metal shards or loose metal parts of your machines, equipment, tools and utensils due to wear and tear then no need to use it but if you don't, a metal detector is a machine which can help you.

[dell]

thank you ajahmoh

so this mean no other way...


is there any alternative?

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[ajahmoh]

other alternative are x-ray or a magnet...but i recommend metal detector..just make sure that the metal detector you are going to buy fits the height of your cake...are you trying to implement a HACCP System?

[dell]

hello my dear
yes.. as a requirement in the implementation of ISO 22000

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[Charles.C]

Hi Almaskati,

 

 Post 2 may be relevant to yr situation.

 

The point is that if you can demonstrate, ie risk assess/validate, that for your process you have sufficient manual control of the operations to prevent contamination in the finished product it may not be necessary to install a MD.

 

For example, for Seafood, from memory, the FDA's Fishery Guide details various requirements which for some processes  may be suficient to control potential metal contamination in the absence of a MD

 

The difficulty is that in many locations, and particularly for RTE products, auditors routinely do see MDs in certain Industries so will require a very high quality documented justification for non-usage. If MD's are rare in yr specific location/industry yr auditorial situation/expectations may be different.

 

You might also consider looking for a second-hand MD, I think they are available.

[dell]

many thanks Charles

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[clover]

Hi Almaskati, 

 

like the rest has mentioned, it's certainly not compulsory and depends on whether you have any other ways of eliminating that risks of having metal items in your finished products. But I would say having a MD is rather common these days, especially in manufacturing facilities.

 

If you're thinking of going for a MD, you will need to think about the metal piece specs as in 2.0 ferrous, 3.0 non-ferrous, 3.5 stainless steel. Maybe your supplier may be able to help you with establishing it but I think that's an important aspect that will determine whether this metal detection step is effective or not. 

[dell]

thank you all

but any thought about the alternative ways of eliminating the risk of metal other than magnet and x-ray?




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[Charles.C]

thank you all

but any thought about the alternative ways of eliminating the risk of metal other than magnet and x-ray?

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You modify the process to avoid use of metal.

[GMO]

It depends upon risk and who you're supplying / where you're based.  So, for example, in the UK, you would probably be perfectly legal not using a metal detector if you are a small manufacturer without many metal risks in your production and you were supplying consumers directly not major retailers.  As soon as you start going down the line of metal mixing bowls, slicing machines etc, the metal risks increase dramatically and a metal detector would be strongly advised.  If you move onto supplying business to business or major retailers, a metal detector will then be an expected requirement.

 

It is important to remind ourselves though that metal control does not start and end with equipment to remove metal.   There are a myriad of other ways to control metal which are, if run well, preferable to metal detection in actually controlling metal. 

 

For example:

 

pre and post operation checks (e.g. pre start checks on machinery, cleaning checks for damage, pre and post checks on knives)

control of maintenance activities (e.g. in a separate part of the production area well away from food, controls on counting in and out screws when having to work on machines, post maintenance hygiene clearance.)

control of suppliers (what do they do to control metal?)

response to incidents (root cause analysis to resolve)

etc...

[sdavies2008]

Metal detectors do not have to be a CCP especially in FSSC22000. The oPRP controls the hazard but does not ensure complete control of the hazard. Loss of control does not ensure a food safety hazard is present.

Prescribed verification activities confirm the detector is operational but does not ensue that a metal hazard will not be present.

oPRP reduced the likelihood of a known hazard to a lower or acceptable unit.

Orientation effect and aperture sensitivity play a role in whether or not an object will be detected.

 

In terms of other ways to reduce the hazard, you need to do a risk assessment and determine the measure you can put in place to reduce the risk to an acceptable level. Do you sift the final product? Would it pick up anything?  How many complaints have you had for metal?

 

There is so much that is possible in terms of determining your risk to determine what your need is.

Sarah

[dell]

🌼very useful information from you all

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[Charles.C]

Metal detectors do not have to be a CCP especially in FSSC22000. The oPRP controls the hazard but does not ensure complete control of the hazard. Loss of control does not ensure a food safety hazard is present.

Prescribed verification activities confirm the detector is operational but does not ensue that a metal hazard will not be present.

oPRP reduced the likelihood of a known hazard to a lower or acceptable unit.

Orientation effect and aperture sensitivity play a role in whether or not an object will be detected.

 

In terms of other ways to reduce the hazard, you need to do a risk assessment and determine the measure you can put in place to reduce the risk to an acceptable level. Do you sift the final product? Would it pick up anything?  How many complaints have you had for metal?

 

There is so much that is possible in terms of determining your risk to determine what your need is.

Sarah

 

Hi Sarah,

 

IMO, this statement is misaligned to the requirements of the iso22000/iso22004 Standards.

 

I find it difficult to see how you can validate a control measure which specifically does not control a significant hazard. Maybe by defining a "reduced" validation ?.

 

However i do agree that some publications share yr opinion.

 

After 10 years, just goes to show what a mess the ISO organisation have made in explaining their semantically ambiguous  Standard.

[clover]

I'm not quite sure and familiar with the terminologies oPRP (?) but just wondering if a metal detector doesn't help to ensure complete control the hazard, then what's the use of buying and using one? 

 

Other than that, you've brought up some good points 

Metal detectors do not have to be a CCP especially in FSSC22000. The oPRP controls the hazard but does not ensure complete control of the hazard. Loss of control does not ensure a food safety hazard is present.

Prescribed verification activities confirm the detector is operational but does not ensue that a metal hazard will not be present.

oPRP reduced the likelihood of a known hazard to a lower or acceptable unit.

Orientation effect and aperture sensitivity play a role in whether or not an object will be detected.

 

In terms of other ways to reduce the hazard, you need to do a risk assessment and determine the measure you can put in place to reduce the risk to an acceptable level. Do you sift the final product? Would it pick up anything?  How many complaints have you had for metal?

 

There is so much that is possible in terms of determining your risk to determine what your need is.

Sarah

[dell]

oPRP stands for: operational prerequisites programs

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[clover]

Hi Almaskati, 

 

yup I know that oPRP stands for Operational Prerequisite Programme but not too sure what's the difference between oPRP vs PRP. And someone once mentioned to me that PRP = GMP....can someone shed some light on this? 

oPRP stands for: operational prerequisites programs

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[GMO]

I'm not quite sure and familiar with the terminologies oPRP (?) but just wondering if a metal detector doesn't help to ensure complete control the hazard, then what's the use of buying and using one? 

 

Other than that, you've brought up some good points 

 

CCPs are required to control a hazard OR reduce the risk to an acceptable level.  So for example, with a cooking process, you don't sterilise the item but you do cook to, say, a 6 log reduction in Salmonellae.  With metal detectors they are not perfect, detection depends on metal type, orientation etc.  For that reason, some people think of them more as monitoring that all of your other controls are effective and certainly the investigation of what is found in them is vital.  That said, there is a question in most HACCP decision trees which says "is the process step specifically designed to eliminate or reduce the hazard to an acceptable level" and I struggle to find a way of saying "no" to that question as soon as a metal detector is in place.

 

I think the answer is some pragmatism.  Is it an absolute requirement?  No.  Is it advisable?  In most organisations, yes.  (And I say this having been supplied by someone who didn't think they needed one for us to find metal in their ingredient.)  It's a business protection tool.  If you have one, is it a CCP?  Probably.  You can argue the toss all you like but if you get audited as much as I do, I see no point in being a trail blazer that it's not a CCP.  If I made it not a CCP, would I control it any differently?  Nope.  Would making it a PRP or oPRP have a negative impact on how it's viewed and respected by factory staff?  Probably.  So the pragmatist in me says, in most cases, get one, make it a CCP but actually control earlier in the process is just as important if not more so to me.

 

Hi Almaskati, 

 

yup I know that oPRP stands for Operational Prerequisite Programme but not too sure what's the difference between oPRP vs PRP. And someone once mentioned to me that PRP = GMP....can someone shed some light on this? 

 

I'm not that familiar with ISO22000, however, as I understand it, an oPRP tends to be more located in a defined position in the process, for example, sieving.  It's reducing a hazard but perhaps not to the level where you'd define it as a CCP.  That said, I said at the time when it came in that it was a fudge factor for people who can't make decisions and I still feel a bit like that about it.  Again, I come back to would I control it differently if it was an oPRP?  No.  So what's the benefit?

[Charles.C]

Can see this recent short thread just to illustrate an infinitely open-ended topic -

 

http://www.ifsqn.com...ose-of-an-oprp/