Metal Detection - is it a Monitoring Activity or a CCP?
METAL DETECTOR: A Monitoring Activity or a CCP?
Generally, most companies in the food industries today have Metal Detectors in their process lines designed for the purpose of detecting metal hazards. Often this step of the process is considered significantly risky to be classified as a CCP (Critical Control Point) - most food auditors insist it is anyway. :dunno:
The issue that I am arguing here is that a Metal Detector does not "change the product or ingredients" in shape, by improvements, in aroma, or product enhancement or alterations of any sorts". Instead, all that it does is to alert any presence of ferrous hazards in the product when detected.
And, when ferrous hazards are detected, it is often at the end of the procees line meaning it is way too late hence, rendering the product not safe for public consumption.
The argument here is if a Metal Detector is deemed a CCP, where and what is the CONTROL POINT that support the process step in making food safe or to be safe?
Unlike a sieve which does change the shape of the product or ingredients, why then should we classify a Metal Detector as a Critical Control Point when itself is NOT a Control Point in the Process at all.
If we agree to this line of argument, shouldn't we correctly classify the Metal Detector as simply a monitoring function and as important as it is, be termed as a "Critical Monitoring Step" instead of a "Critical Contol Point / Step" or as I like to term it "Quality Control Point"
As a "Critical Monitoring Step" it would just be a record keeping procedure whilst categorising it as a CCP would certainly attract the auditor's attention and viewed from a more serious angle. (Mind you, calibration remains a requirement anyay you take it)
What is the general consensus? A "Critical Monitoring Step / Quality Control Point"" or a "Critical Control Point" ?
Cheers :doh:
Charles Chew
CharlesThe issue that I am arguing here is that a Metal Detector does not "change the product or ingredients" in shape, by improvements, in aroma, or product enhancement or alterations of any sorts".
Is this your definition of a CCP or is it a quote from somewhere else?
I know what you're getting at, unfortunately I would have to agree with the food auditors.
If you go by the CODEX guidelines a CCP is:
"A step at which a control can be applied & is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level"
If you follow the CODEX decision tree
Q1 - Do control preventative measures exist?
A1 - Yes
Q2 - Is this step specifically designed to eliminate or reduce likely occurence of hazard to an acceptable level
A2 - Yes
Outcome - This is a CCP
Regards
Richard
However it is you and your HACCP team that know most about the risks in your factory not an auditor who is only on site for a day or two.
If you can say that there is not a significant risk of metal contamination or metal contamination can be controlled at a previous step then metal detection is not a CCP.
If you are 100% confident in your HACCP and the way the study has been carried out then you should stand up for yourself against the auditors. What your team say is a CCP is a CCP
Because most food machinery is made out of metal then there is a risk of metal contamination which is most usually controlled by metal detectors.
My big question in metal detectors is do they reduce the hazard to an acceptable level? <_<
Do we feel that a 3mm piece of stainless steel is not a hazard?
You are spot on. Yes, a Metal Detector is indeed a CCP and your quote on Codex is indeed brilliant. I was trying to stir up some minds out there but you are too good.
Although, a metal detector is not part of the main production process steps, it is a direct and deliberate intervention step designed to control ferrous hazards which has been pre-identified as a potential hazard.
And, the issue raised by Yorkshire is relevant too. There are two types of magnetic detectors a) one that picks up ferrous metal during the process which depends on the magnetic gauss strength - usually very high e.g. found in powder process as in Cocoa Powder Manufacturing Industry etc B) The other type "detects" presence of ferrous metal which depends on the magnetic flux strength and these are found normally in meat based products etc.
With this, I wonder if we can still have an argument with the food auditor and get away with it? I too do not think so.
Charles
Simon
For myself (as a packaging producer) - the issue of metal detectors is not a big one. We do not have them and are not considered as a CCP (subsequent step will eliminate).
DOH - Just realised I've got metal bolts as a CCP - will have to change my CCP list.
Would be interested to know - Do any packaging producers out there use metal detectors?
Regards
Richard
I guess doing a specific internal audit on the potential introduction of metal hazards could be a good idea. Afterall, the risk level of the products escalates when more CCPs are present.
Since you do have a metal Detector as a CCP, I assume there is food contact which makes it necessary to consider justifications for such potential metal hazards to be introduced.
"Intervention steps" could render CONTROL on the risks of such hazard introduction like metal bolts which may be just potential hazard but can be controlled and effectively removed as CCP
Unless you have the burden of a historical incident, it is a good idea to maintain the Metal Dectector since validation requires only calibration and record keeping is simple enough.
Sadly, not enough packaging companies are using metal detectors.
Charles Chew
IMHO the point is if the metal contamination in your plant has random origin or somewhat specific origin.
For instance, suppose you know there is the possibility that misuse of screwdrivers may result in falling into the bulk food at a specific step of the process and you also know there are no means of reducing the risk in subsequent steps.
The step is a CCP according to Codex approach.
You should make up a list of screwdrivers and ensure that they are constantly controlled.
If you put a metal detector after that step, then you only monitor the effectiveness of the previous control (the list) because primary source of contamination, screwdrivers falling into the bulk food, is the one you should control as a CCP.
If the contaminations appears to be of random origin, then metal detection is a CCP.
Good point but you missed the that each screw should have a unique code embossed on the side and signed out to a suitably trained person.
Seriously though a major UK supermarket was prosecuted after a customer found a chisel in a product ( I think it was a loaf of bread ), the product + the chisel were so heavy that the air blast on the metal detector was unable to blow the product off and went out to the customer!
Wasn't the 'chisel bread' part of the same product launch as the 'mouse bread'. Strange that neither caught on. Sorry I couldn't resist using the image again.
Regards,
Simon
Attached Files
Loose tools and other items that are specific are normally controlled by means of recording at entry or issue point and accounted for upon return. Not forgetting the need to perform risk evaluation and control procedures for any "new " loose tools or items" that may be introduced.
Even in the area of microbiological control specifications, we had successfully removed a CCP at a temperature control storage point where we deliberately intervened by lowering the critical temperature further.
By this intervention step, frozen products that were stored above the "new" temperature parameter resulted only in a quality issue but NOT a food safety risk issue.
Loose tools are risky and dangerous but can be controlled and as such, not normally considered a CCP in a hazard analysis but rather a potential source of hazards.
Regards
Charles Chew
What is the end use of the material to which the HACCP study relates? Is the packaging item intended for consumption?
Since you do have a metal Detector as a CCP, I assume there is food contact which makes it necessary to consider justifications for such potential metal hazards to be introduced.IMHO there should be a differentiation between food contact and non-food contact items of packaging. The source and nature of the contaminant should be the factor used for risk assessment.
Metal Inclusion
If metal is an 'inclusion', or 'encapsulated' within your product, what's the danger to the consumer?
Contamination of this nature tends to occur at 'wet end' operations. Consideration should be given to prevention of contamination around this area, and an assessment of size of contaminant (if fitted, screens/filters, injection point size etc. will determine likely size of inclusion).
Do we feel that a 3mm piece of stainless steel is not a hazard?
Size is important!!!! :off_topic:
I am assuming the recipient of your materials is a food producer??? They are highly likely to have metal detection.
It will be a pain in the proverbial for your customer if they metal detect at a higher sensitivity than you. In the event of contamination, they may have to stop production lines to investigate source, or who may reject your product. It may be a $$$$ issue, not a food safety issue. This type of contamination would label the detection process as a QCP.
Loose / Exposed Metal
If the metal is loose within the packaging, or sticks up out of the packaging and has the potential to contaminate the ingestible component, or to injure the consumer, then it will be an issue.
Whilst GMP systems to prevent contamination of this nature should be considered, metal detection IS a CCP!!
Indeed a metal detector is a CCP regardless. Interestingly, in a cocoa powder manufacturing facility where metal detectors are all over the entire piping line, where should the CCP be?
Regards
Charles Chew
Are they detectors? Or magnets? Is a separate rejection system included?....in a cocoa powder manufacturing facility where metal detectors are all over the entire piping line, where should the CCP be?
My opinion...
CCP - Magnet
Critical Limit - >0.5g catch per day
Monitoring Procedure - Collect and weigh magnet catch
Records - Weight trend analysis / charting
Verification Procedure & Frequency - Test strength of magnet (??) Monthly
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action.
CCP - Detector
Critical Limit - >0 count. Detector sensitivity 0.5mm Fe/non-Fe/St-St
Monitoring Procedure - Audible & visual alarm at detection
Records - Detection count record. Functionality check record
Verification Procedure & Frequency - Detector functionality check every hour
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action.
CCP - Rejection System
Critical Limit - >0 rejections. Detector sensitivity 0.5mm Fe/non-Fe/St-St.
Monitoring Procedure - Audible & visual alarm at detection
Records - Rejecter count record. Functionality check record
Verification Procedure & Frequency - Detector and rejecter functionality check every hour
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action.
Very impressive!
Regards,
Simon
Thanks for the infor.....looks real good.
Questions:
1) We have about 15 Magnets with 10,000 Gauss strength spread over the entire pipe line through to final bagging. Do we treat all as CCPs and if not, which one should we identify?
2) Your indicated Critical Limit of >0.5g per day (I assume that you meant <0.5g per day), we would need to have the reference to support this setting.
3) Should the weight trend analysis be based on cummulative or a single source collection over the 15 magnets?
Hear from you soon.
Regards
Charles Chew
My response was not based on experience so I can' t really give a definitive answer to your questions, however...
I would suggest that the 'use of magnets' is one CCP (as opposed to each magnet being a CCP in its own right). For CCP monitoring, I would use a total weight of material collected.1) We have about 15 Magnets with 10,000 Gauss strength spread over the entire pipe line through to final bagging. Do we treat all as CCPs and if not, which one should we identify?
No - I meant ‘>', IE: anything ‘>' x.xg would be ‘out of spec'2) Your indicated Critical Limit of >0.5g per day (I assume that you meant <0.5g per day)
Yes - I'm afraid my figure of >0.5g was pulled out of thin air - I cannot substantiate!!.....we would need to have the reference to support this setting.
I would suggest cumulative would give better results3) Should the weight trend analysis be based on cummulative or a single source collection over the 15 magnets?
Hope this helps
Back from my holidays at B&Q.
I feel that Charles may be playing Devil's advocate here.
Are we really suggesting that all 15 magnets, sieves, metal detectors, or whatever are all CCPs?
If your first magnet fails are you going to hold all product for a whole month?
Making challenges is what effectively brings the best out of any forums and its members. Fiona's contributions were appreciated and nobody can say she is wrong unless with valid reasons.
You are right that I was playing devil's advocate. However, I wish to add that normally the final(15th) Magnet should be the CCP while the 14 others are not but remained subject to monitoring.
The thorniest question is probably about validating the Critical Limit (say it is 10,000 Gauss) for the 15th Magnet before production starts. The other CL is probably having an operatable Magnet (assuming it is electrically operated) which is simple enough. Comment please?
Cheers
Charles Chew
I wanted to resurrect this thread since we have a metal detector on the way with a rejection system, I believe. I am not sure if I am correctly interpreting Fiona's post quoted below or not. What I am interpreting or misinterpreting is that any time metal is detected and/or rejected, the corrective action is to quarantine the food and investigate.
The reason I ask is that we currently use 2 magnetic spouts at the end of 2 conveyors. The last magnetic spout is considered our critical control point. We always have some quantity of small parts after a run in the magnet.
So my question is this: Is it a bad idea to consider that your metal detector / rejector is protecting the product? When metal is detected and rejected, we can't consider the apparatus is doing it's job and we can go on producing?
Sorry if I am unclear, and I would appreciate any clarification.
CCP - Detector
Critical Limit - >0 count. Detector sensitivity 0.5mm Fe/non-Fe/St-St
Monitoring Procedure - Audible & visual alarm at detection
Records - Detection count record. Functionality check record
Verification Procedure & Frequency - Detector functionality check every hour
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action.
CCP - Rejection System
Critical Limit - >0 rejections. Detector sensitivity 0.5mm Fe/non-Fe/St-St.
Monitoring Procedure - Audible & visual alarm at detection
Records - Rejecter count record. Functionality check record
Verification Procedure & Frequency - Detector and rejecter functionality check every hour
Corrective Action - Quarantine materials packed since last acceptable check. Investigation, and implementation of preventative action.
Thanks,
Doug
What product are you processing?
We manufacture high protein snack chips and pretzels. Here is an abbreviated idea of our process:
soya protein, tapioca, starch (other bags in powder-like form)->Mixer->Extruder->Main dryer->Seasoner / Oiler->coating dryer->packaging
The first magnet spout catches the majority of the particles. The chips then go through a sifter to sort out overs and unders and then to the last conveyor with a magnetic spout which usually has a small quantity of fine sand-particle size pieces.
The new setup will probably be:
Bag Dump->Blender->Pneumatic conveyor with inline magnet->Product receiver->K-tron product scale-weigher->Extruder->pneumatic conveyor->Dryer->1st conveyor with magnetic spout->Sifter->2nd conveyor with magnetic spout->Metal Detector / rejector->Tote
The reality of our current setup is that the metal detector will find and reject small rust pieces. My question is: Do we look at this metal detector / rejector as something that is taking care of the problem or simply telling us we have a problem?
Thanks,
Doug