HACCP step Metal detection help
Hello all, I work in a nut processing plant in the USA and we had metal detection as a CCP, but then "powers from above" decided it would be better (despite my arguing to not) to have a risk analysis proving we didn't need it as a CCP to justify buying a metal detector that is not as sensitive as our other ones (basically adding 1mm to minimum detection size for Fe, non-Fe, and SS).
long story short we need to make metal detection a CCP again, and I'm wanting to remove the old metal detector from the system as It does not meet the testing requirements set in our HACCP plan (1.5mm Fe/non-Fe, 2.0mm SS per our haccp / 2.5mm Fe, 3.0mm Non-Fe/SS is the new MD) . We can't just make our requirements that of the larger test pieces because it doesn't meet customer requirements that I'm expected to meet but my boss is trying to argue that we don't need to run product through a metal detector because we have an x-ray detector prior to packaging (even though our metal detection step is after packaging and therefore a different step in the process at any rate, but no one wants to listen to me any way). Is there any way to actually justify this?
I was thinking possibly making the CCP the step of metal removal via detector or x-ray and validating the x-ray to the same metal standards but I know x-ray detector will not pick up aluminum because it's not dense enough so then I run the problem of proving there is no risk of aluminum contamination (which would require much more control over the maintenance crew than anyone in our plant has).
Does anyone have any thoughts on how I can make this work or have any thoughts on what I can say to hopefully convince my boss that we just need to nix the old detector from our system if we are expected to meet customer requirements. even repeating what I'm saying in a comment below and agreeing (as long as you actually agree and help me in my cause) would help to show our "powers from above" others within the industry agreeing with me. or not agreeing and however we can make this work, I'm more than happy to be wrong as it seems like it could be less stress in my life.
Have you performed the risk assessment after the X-ray, to determine if metal can be introduced in some form or another? You mentioned aluminum, I assume you have a lot of aluminum in your facility that may contaminate? Look at it from an auditor perspective, if your regulation or customer requirements are bound by a certain guideline, you'll have to show evidence your containment / qa processes are capable of detecting said particulates. Do you have documented incidents of aluminum shavings, damaged equipment etc. that contaminated product with aluminum in the past? That there should be enough justification as you mentioned the X-ray doesn't detect aluminum.
If you can prove to yourself, and to an auditor / regulatory auditor / customer there is no risk of aluminum (or other contaminates) to contaminate your product to an unacceptable limit, then I think you could document accordingly to justify removing your metal detectors.
You can also apply ncorliss' logic to this issue from a FDA regulatory standpoint. Based on your facility's history, sister facilities' history, FDA issuances & compliance guides for your type of process, etc., what is the risk of metallic FM in your process flow? If low risk, then you can logically change from a CCP to something else. Then there are your customer's requirements/expectations - if your MD program does not meet them, you run the risk of losing their business...
KTD
If your product has to run through both the X-ray and metal detector do you have the option of putting the metal detector prior to the x-ray to detect any aluminum? This could work if you did not have any aluminum contamination points after the metal detector.