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FSMA - Optical/Laser Color Sorter as Preventive Control

FSMA PCHF HARPC Color Sorter Validation Preventive Controls mycotoxins

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#1 GrainGirl

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Posted 28 November 2017 - 10:23 PM

Hi all,

My company, which is in the U.S. and re-packs dry ingredients such as pulses, grains, and seeds, has recently purchased a laser color sorter as a way to control for foreign objects in incoming bulk product. We are subject to the Hazard Analysis and Risk-Based Preventive Controls rule (HARPC) - also known as the Preventive Controls for Human Food rule (PCHF) - under FSMA. In our hazard analysis we identified foreign objects (e.g., stones, metal, debris) as a potential food safety hazard for most of our incoming ingredients (it should be said that we do have finished product metal detection in place).

 

I realize that foreign objects can be seen as a quality issue, but on the conservative side they can also be food safety hazards if big enough, sharp enough or hard enough. If I recall correctly off the top of my head, the FDA will consider food adulterated if it contains foreign objects larger than 7mm. So we have taken the conservative approach and have identified foreign objects as potential food safety hazards. 

 

We are trying to determine if the laser color sorter can be considered a Process Preventive Control to control for foreign objects as potential food safety hazards. If yes, we must also validate that the preventive control is "adequate to control the hazard as appropriate to the nature of the preventive control and its role in the facility's food safety system."

 

 

So, my questions are: 

 

1. Has anybody out there identified their optical sorter or laser sorter as a preventive control? Or is it really better classified as a GMP/PRP?

2. How does one validate a color sorter? 

3. As a "bonus" question, has anyone used color sorting as a control for mycotoxins (i.e., for culling moldy grains/seeds)? If so, is it possible to validate for this?

 

Thanks much!

 

 

 



#2 SQFconsultant

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Posted 29 November 2017 - 02:50 AM

So, my questions are: 

 

1. Has anybody out there identified their optical sorter or laser sorter as a preventive control? Or is it really better classified as a GMP/PRP?

2. How does one validate a color sorter? 

3. As a "bonus" question, has anyone used color sorting as a control for mycotoxins (i.e., for culling moldy grains/seeds)? If so, is it possible to validate for this?

 

------------

1. Client uses a combo LED/Optical Laser sorter as a preventative control in a fresh (right off the boat and onto a conveyor that shoots thru the sorter) shrimp processing facility in Mississippi and it kicks out the ones with black spots, discolors (normally meaning that ice was not applied properly in the holding bins onboard the vessels) and damaged shrimp.

 

2. Interesting enough the manufacturer provided validation studies and wrote the validation for their current GFSI certification.

 

3. Sorry, bonus does not apply. darn.


Kind regards,

 

Glenn Oster
 
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Also tagged with one or more of these keywords: FSMA, PCHF, HARPC, Color Sorter, Validation, Preventive Controls, mycotoxins

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