New metal detector with audit right around the corner

Good morning

I am looking for some feedback from all of the experts out there please!

We are having our first BRC audit in 3 weeks.  We are a small operation that handles only raw meat, and in essence we are a large butcher shop with some packaging equipment that we load by hand (no running lines).  In the history of the company (over 40 years), we have never had metal detection.  In the past year we have implemented documented checks on the knives, saws, and pinning machine, and these are all visual checks.  We use customer findings/complaint review to support that we are controlling this potential hazard.

I brought up (again) to senior management that I wasn't sure how our auditor would view the management commitment to food safety and our process for foreign material control without metal detection.  Without my knowledge. we apparently have now purchased a new metal detector that will be arriving in 1-2 weeks.  In most instances, this would be a good thing.  Right now though with the audit so close, my head is spinning because I don't see how we can get it installed, everyone trained, reassess the HACCP Program and have documented procedures before the audit.  

So my question to you - do we go with what we have right now, tell the auditor we have purchased a metal detector to improve our food safety going forward, and implement after the audit.  Or try like heck to get it all done before the audit - 

All comments are appreciated - 

Good morning,

I understand BRC requires at least 3 months worth of data (records, checklists, monitoring proof, etc.) to consider a program being implemented. For transparency sake I would inform auditor you will be installing New Metal Detector. If required by auditor, justify the installation decision with the documents you have sent Senior Management Team in regards approving purchase and installation. Maybe have a Purchase requisition and a Maintenance Work Order to demonstrate purchase and installation activity is programmed. Technical Data Sheet and Metal Detection standards are always useful. Future HACCP Plan and Process Flow Diagram indicating where it will be located also can help you and auditor will see you are being proactive.

You can get a lot of work done before the metal detector arrives - on the paperwork side at least

Do you have any test pieces arriving with the metal detector so you can conduct challenge tests?

Thank you for the replies

Ivar yes my understanding is the same as yours that we need at least 3 months of data.  I will take the idea of at least having the flow chart outlined to show where it will go (which is also still a bit up in the air) and the purchase order with the notes from our meetings.  

Chris - no test pieces have been ordered yet - I'm waiting on specs for the metal detector.  I'm hesitant to order because we will be detecting the product in it's final box, and the boxes are different sizes.  We may have different requirements depending on the sensitivity and set up of the metal detector.  

Thank you for the replies

Ivar yes my understanding is the same as yours that we need at least 3 months of data.  I will take the idea of at least having the flow chart outlined to show where it will go (which is also still a bit up in the air) and the purchase order with the notes from our meetings.  

 

Chris - no test pieces have been ordered yet - I'm waiting on specs for the metal detector.  I'm hesitant to order because we will be detecting the product in it's final box, and the boxes are different sizes.  We may have different requirements depending on the sensitivity and set up of the metal detector.  

Hi Peaches,

Can try asking the Engg department for a few measurable Fe/SS ball-bearings in the appropriate size range to place in a box if you want some idea of the sensitivity. Use a Box of different colour to Production of course.

"So my question to you - do we go with what we have right now, tell the auditor we have purchased a metal detector to improve our food safety going forward, and implement after the audit."

YES. 

I agree that the timings are too tight.  You are likely to get a non conformance on poor control of the metal detector (because someone will do something wrong) rather than not having it but getting people trained etc.  Also you have to remember the time taken to get this in well will draw you and the team away from other priorities.

So what I'd do is have a HACCP meeting, discuss that it's coming in, start writing a metal detection procedure etc.  Then when it comes in, get the contractor to install, calibrate and train you then you can finish your procedure ready to train out to the team once BRC is complete.  Minute all of this in your HACCP meeting to explain why and I'm sure it will be fine.  If you've been ok with metal controls up to this point I see no reason why an auditor would raise a point now and, if they did, at best it would be a minor IMO.  Once your metal detector is in place, you'd need to consider whether it is a CCP with your HACCP team.  Do not assign it as a CCP before the audit though or you'd be in critical non conformance territory!  In reality we all know that metal detectors should really never kick anything out so your controls you already have are probably enough but we also all know that they never are.  So while I'm saying you'd be fine for this audit, I do agree with getting the metal detector as a decision.  One thing to be careful of though as your HACCP team is once that detector is in place your other controls may start to slip.  The attitude of "oh well the metal detector will pick it up" may be an issue and that's a very important part of the training which is one of the (many) reasons you shouldn't rush it.  Metal detectors are not perfect.  They only detect pieces above a certain size (and that may be bigger than your ballbearing test piece by the way as not all contaminants are perfect spheres and not all shaped pieces will be detected equally.  Thin, long pieces can be particularly difficult.)