13 replies to this topic

[Remi.Trepanier]

Good Morning, if I consider my metal detector part of our Prerequisite program (As per CFIA Food Safety Enhancement Program G2.1.2), do we still need to do a validation of the metal detector if it is not a CCP?

[Charles.C]

Good Morning, if I consider my metal detector part of our Prerequisite program (As per CFIA Food Safety Enhancement Program G2.1.2), do we still need to do a validation of the metal detector if it is not a CCP?

 

I’m not in Canada so this is speculative but from FSEP manual I suggest that "validation" may be equivalent to the requirements of  section C.1.1.1

 

This is an old example (2006) but I noticed this comment in an audit –

45/51.    Metal detectors are not Critical Control Points in this establishment; however, when the probes were run through to determine if the instruments were functioning properly, this was not recorded. Therefore, there was no way to determine by records if the detectors were functioning correctly. FSEP Manual, Chapter 2, Sections 4.6.2,4.8.2,4.8.5

(above sections seem to no longer exist in current FSEP manual)

[KTD]

Dear Remi -

 

Whether a CCP or in prerequisite program, there is an expectation that your food safety equipment/processes are validated to ensure and demonstrate that they are operating properly to mitigate the hazard. For example, BRC explicitly requires this.

 

KTD

[Scampi]

Ok, so as per FSEP, you DO NOT NEED TO VALIDATE. However, that does not mean you do not need to VERIFY

 

So, you need the manufacturers instructions for calibration, and you metal detector belong also in C.1.2.1 as the detector also needs to be calibrated on a regular schedule---this is separate from daily monitoring when you ensure that the predetermined metals are kicked off (or however you know it's working) at regular intervals based on line speed

[Charles.C]

Good Morning, if I consider my metal detector part of our Prerequisite program (As per CFIA Food Safety Enhancement Program G2.1.2), do we still need to do a validation of the metal detector if it is not a CCP?

 

Hi Remi,

 

I think there is agreement that in the context of the FSEP manual which only requires validation documentation for CCPs, the answer to OP is NO.

 

i am however intrigued regarding yr risk assessment to justify that the MD is not a CCP though. I daresay CFIA will be also.

[Scampi]

Sorry Charles, but CFIA will not object to it being a process control and not a CCP-----as per FSEP, 

 

G.2.1.2

Where applicable, the establishment has and implements a documented program for

monitoring equipment such as filters, sieves, magnets, metal detectors, x-ray equipment,

optical sorting equipment, scanner technology, in-line container cleaning, etc. that is/are

used to detect and/or remove foreign materials. The program includes but is not limited

to: etc etc etc

 

So, if there were not other controls, than yes metal detection would need to be a CCP otherwise it is an acceptable process control

[Charles.C]

Hi scampi,

 

I daresay it also relates to where the MD is located. And the Product. And the Process.

 

= Risk Assessment.

[Scampi]

Yes, but CFIA will not force you to put a CCP in your program simply because it is a metal detector. The combined form 8 that is required will in itself dictate whether or not a CCP is required to reduce/eliminate the hazard 

[Charles.C]

Yes, but CFIA will not force you to put a CCP in your program simply because it is a metal detector. The combined form 8 that is required will in itself dictate whether or not a CCP is required to reduce/eliminate the hazard 

 

No Problem.

Hopefully the OP will return and explain his logic.

[Remi.Trepanier]

Good Afternoon, I just remove our metal detector. It was our only CCP, but Prerequiste G of FSEP has foreign object control. I don't see the point of having that as a CCP. I heard from our BRC Auditor that USA has to have at least one CCP, but it is not the case for Canada. Is that true?

Edited by Charles.C, 29 March 2017 - 08:28 AM.
moved from 422

[Mulan1010]

I am not sure about Canada regulations but it seems like the US and Canada are pretty close in requirements.  In the US under USDA you are expected to Validate the pre-requisite programs you use to support your HACCP Plan.  The Pre-Requisites only have to be validated once, unless there is a major change like the CCP's but unlike the CCP's you don't necessarily need testing done.  You can find supporting articles and make sure you are able to meet the parameters of the article.  It would not hurt to check the guidance out and see if that might be helpful in what you are looking for.

 

From the Guidance, pg 14: "For physical hazards, the scientific support should closely match the physical hazard being controlled. For example, if the establishment uses detection equipment to identify foreign material such as metal in a particular product, the data used to validate the detection system should demonstrate that the equipment can in fact detect the targeted materials (e.g., metal of a defined size) in the product." - To validate this you should be able to find an article or maybe even a government document to set a parameter as to what size and material is considered unsafe and then have documentation from the manufacturer as well as tests done by the manufacturer to validate that the detectors will pick up that size and/or even smaller.  Then you can verify the detectors in use at the determined set interval to show they are detecting the standard size set and the type of material (ferrous, non-ferrous and/or stainless steel).

 

[Charles.C]

Hi Mulan,

 

Regarding Prerequisite Programs/yr example, perhaps more like Chalk and Cheese ?

 

In general, I suspect that every Organisation makes it’s own rules where “validation” is concerned. Including sources of FS Standards. The reason is that a myriad of  interpretations for (a) the requirements and (b) the implementation of the term "validation" exist. Typically FS schemes are “based on” Guidelines like NACMCF/Codex but  with individual tweaks.

 

Not a user but I deduce that from FSEP’s 2014 Manual, clause 3.3, CFIA’s required “validation documentation” apparently does not involve PRPs except perhaps via one caveat – “CFIA may request validation documentation for any control measures within the HACCP system that have an immediate impact on food safety.” Hmmm.

 

With respect to implementation, I think USDA/FSIS’s detailed validation requirements  as per attachment below are unique to themseves. But at least they do “seem” to be prescriptively transparent.

 

 

 FSIS 78-15, 2015, Verifying Compliance with Validation Requirements.pdf   70.08KB   72 downloads

[Scampi]

When you have a section 4 audit (the entire HACCP system) the audit will or will not determine that your thinking is correct and/or safe. The entire point of a CCP is to add control when none other exists, upstream or downstream. 

Assuming you have used the Form 8 correctly (or a combined form 8) IT SHOULD dictate whether or not a CCP is required.

 

So the short answer is NO-there is not a Canadian requirement or assumption that a CCP IS required in each and every plant. Believe you and me, if I could remove mine, I would as well, but alas my form 8 won't let it be so

 

Simply adding a CCP to appease an auditor is shear silliness to me. Any auditor worth his/her salt should be looking at the entire program and it's effectiveness regardless of whether or not a CCP is present.

[Scampi]

Remi, just do not forget to also reassess the entire system now that you have removed the CCP, you must log your change and all associated documentation that will change as a result. IF YOU DO NOT THIS WILL BE A CAR from CFIA during your next audit