199 replies to this topic

[AS NUR]

dear all...

IMO... to make decision on mD as CCP or as monitoring only, depends on your hazard analysis.. if your MD to protect your finish product from any metal contamination.. thats MD is CCP.. but if you have another process after MD to protect from metal contamintion you can put your MD as OPRP ....

[DavidB]

METAL DETECTOR: A Monitoring Activity or a CCP?

This will depend on your HACCP risk assessment for metal in the process. Is metal a hazard in your process? What is the incidence of metal, size and type, sporadic or regular frequency what type of metal etc. etc.

I would not think small amounts of fine powdered rust at this step would consistute a hazard.

If metal is not a hazard in your product then the metal detector at this step is not a CCP, and if it is then it is.

Normally when first implementing HACCP this would be a CCP, and as the process gets improved through better GMP, Vendor Assurance and technologies, the CCP gets reviewed and downgraded to a CP when it is verified that metal is no longer a hazard.

[Erasmo]

A bit of new member solidarity - I agree with you Rey

Although I have to ask does it really matter?

Metal detection can only be described as a monitoring activity if you wanted to make it a CCP the step should be titled "Passing food through metal detector" (to be pedantic)

I must own up to not reading the whole thread but agree with those who state most auditors inspectors demand it is a CCP so I agree to keep them happy.

S

I just dont understand the question for this disscussion...
For requirement, all CCP has to be monitored... see principle 4 or 7.6 from ISO-22000. so, if it's a CCP, it has to be monitored.

[rosie]

Hi Richard

I work for a packaging company and we have metal detectors on some lines.
The detector is checked only once per shift with the test pieces. However it still does not detect small swarf pieces of metal which can form into the plastic and although I don't consider these a food safety risk our main customer would reject an entire batch on the discovery of such a contaminant.

If this applies to you do you consider print verification a CCP or, similiarly, a monitoring step?

[Simon]

Hi Richard

I work for a packaging company and we have metal detectors on some lines.
The detector is checked only once per shift with the test pieces. However it still does not detect small swarf pieces of metal which can form into the plastic and although I don't consider these a food safety risk our main customer would reject an entire batch on the discovery of such a contaminant.

What do you make Rosie?

If this applies to you do you consider print verification a CCP or, similiarly, a monitoring step?

I think this is better as a stand alone topic.

Regards,
Simon

[rosie]

Hi Simon

We make tubs / cartons from polypropylene or polystyrene - plain, printed and sleeved.

Rosie

[GMO]

Ah... I know the reason why they'd reject them! A friend of mine has had huge issues with PP containers with swarf because their detection equipment picks up and rejects the product (containing the foodstuff) as it detects metal in the food. For every reject, there's the investigation, the waste resulting from that and the person's time. It's a huge nightmare for him; so much so that for that reason and also to reduce packaging weight he worked with the marketing department and they've moved to film bagging. So it might not be a food safety issue in that case, but you can't distinguish it from a food safety issue in a real time production environment.

[cazyncymru]

I was to receive a delivery of primary or secondary packaging with pieces of metal in (or foreign bodies), i'd have no hesitation in rejecting the load and i'd want a full investigation carried out. i'd be damn annoyed if the supplier had metal detection but didn't utelise it fully to ensure this kind of contamination didn't happen. I'd also be there at the first oppurtunity to audit to see what else it is their not doing.

if unfortunately any contaminated packaging got out to the consumer, my EHO would instruct the local authority for the packaging supplier to go in and investigate.(in fact in the past, my EHO has investigated a primary packaging supplier of ours who were supplied us with plastic cups that were contaminate with metal- hence why they don't supply us any more)

unfortunately, its not the reputation of the packaging company that is at stake, but that of the manufacturer, which is probably why most of us would almost insist on metal detection being a CCP.

[MRios]

Going back to the matter of magnets:
Our CCP is a magnet immediately before packing corn grits. In 8 years we´ve had one customer complaint about metal in the grits, which we traced to the customer´s production facilities.
The question is: if we do find something on the magnet, does it mean that we have to quarantine all product from the last time we checked?
With finding something I mean: a bolt or a screw, or something else that would indicate that a piece of equipment was falling apart. Sand size particles would not indicate that the equipment would be in danger, but in need of maintenance, I believe.
If the magnet is catching the ferrous material, then it´s doing its job and there would not be any ferrous material in the end product. The corn grits are used by industrial clients, who have magnets in their process.
How do I verify the strength of the magnet?
How do I determine if I have the strength I need according to the rate of product flow?

[GMO]

IMO magnets are not the way to go, for several reasons:

They only detect ferrous metals (high quality stainless steel which is normally used in food facilities will not adhere to the magnet.)

Unless the magnet is cleared regularly, it can build up then "dump" the debris back into the stock without an operator knowing.

The strength of the magnet is dependent on distance from it so a larger contaminant further away will be less inclined to adhere.


I think in answer to your questions; you need to be clear with your customers about what your processes are, however, you cannot rely on your customers to pick up your contaminants because they could easily make changes to their process without informing you. IMO your hazards should always be controlled where possible in your factory.

If your HACCP plan has identified your magnet as a CCP then it should be a hold since last good check because as I've said above; magnets aren't 100% effective.

I don't think you can rely on your low level of customer complaints because your note suggests you don't sell to consumers. If your customers have magnets and metal detection themselves, they may be finding contamination from your site without knowing it's from you (or more worryingly they might be missing it.)

I think in your position I would recommend a throat metal detector (ie a metal detector on a gravity fed pipe). Metal detection is cheap and detects metals other than ferrous. I can't see a valid reason for not adopting it to be honest.

[MRios]

Thank you very much for your response GMO. This will definitely help me discuss with management the need for metal detectors.

[Abdul Qudoos]

It depends upon the product, process and packing line...

If it is risk of metal contamination, like in some cases

• metal scrapes out from the vessel or
• from the cutting machine or
• from the line
• or while using aluminum foil in packing or
• breakdown of the machine/line, metal screw/bolt/nut or fine particles due to rubbing.

As stated above if one or many involved in your process then metal detection is CCP.

or

• Assume just re-packing food products manually
• by blending with other components and packing,
• there is no involvement of automatic machines

then metal detection is a monitoring activity.

Still there are many examples, we need skills and expertise to understand the process.

[Mel Morris]

The CFIA would never permit you to have a metal detector and NOT have it as a CCP. It's easier to justify why you don't need a metal detector at all .Some years ago I was modifying a Liquid Egg Pasteurizing HACCP Plan and the metal detector was useless as any metal prior to the pasteurizer would get blocked by the pasteurizer's small apertures, and immediately after the pasteurizer the egg was pumped into 2000 lb steel totes. The metal detector had been added as a customer request years earlier and noone on staff at the time was capable of explaining to the customer (bakery) why a metal detector was ineffective. Once I presented the CFIA with 7 years of data showing not a single metal contamination incident, they agreed we could remove the metal detector completely and thus reduce our CCPs by one, but they said that if you have a metal detector it must be a CCP.

[Tony-C]

The CFIA would never permit you to have a metal detector and NOT have it as a CCP. It's easier to justify why you don't need a metal detector at all .Some years ago I was modifying a Liquid Egg Pasteurizing HACCP Plan and the metal detector was useless as any metal prior to the pasteurizer would get blocked by the pasteurizer's small apertures, and immediately after the pasteurizer the egg was pumped into 2000 lb steel totes. The metal detector had been added as a customer request years earlier and noone on staff at the time was capable of explaining to the customer (bakery) why a metal detector was ineffective. Once I presented the CFIA with 7 years of data showing not a single metal contamination incident, they agreed we could remove the metal detector completely and thus reduce our CCPs by one, but they said that if you have a metal detector it must be a CCP.

If you are processing a liquid wouldn't a filter be more effective anyway?

Regards,

Tony

[GMO]

If you are processing a liquid wouldn't a filter be more effective anyway?

Regards,

Tony

Filtration can become a source of contamination if you're not careful! The filter IMO should then become a CCP for two reasons, for removal of foreign material and to check that the filter is intact and not dumping additional foreign material into the mix.

It is surprising how many times I've been told there is "no chance" of metal falling in a product and there are all of the prerequisites in place, e.g. preventative maintenance for then a piece of a machine which "never" falls off, to fall off! Interesting I think!

[Tony-C]

Filtration can become a source of contamination if you're not careful! The filter IMO should then become a CCP for two reasons, for removal of foreign material and to check that the filter is intact and not dumping additional foreign material into the mix.

I agree filtration becomes the CCP and needs to be inspected regularly:

a. to check it is intact
b. to check that it is being cleaned
c. to check for foreign bodies which could warrant further action

Filtration can be far more effective than metal detection given that <7mm has been quoted previously and depending on the viscosity of your liquid you can probably get away with a 1mm mesh filter.

Regards,

Tony

[Simon]

This topic has been running for over 5 years now. So can we decide once and for all whether metal detection is a monitoring activity or a CCP?

[AS NUR]

CCP if no further process that can reduce or eliminate the metal... If the further process can eliminate or reduce the hazard to safety level, MD is CP..

[akira]

I've came across with a course talking about Value Stream Manufacturing.

All process steps that result in the same objective is a waste, Over-rocessing.

In this case, metal detector. If you are using metal detector for your incoming raw materials, & in fact you have made an agreement with your supplier in ensuring no metal contamination is allowed in the materials supplied to you, then probably Supplier Performance Monitoring Program (or in a simpler term Supplier Audit) is your O-PRP. If you were buy in another metal detector to verify whether the supplier really do their job, then this is over-processing. In this case, MD, neither as a CCP nor O-PRP is needed in any for your process step.

In other occasion, you were to use the metal detector at your PACKED products in order to reject any finished product that contaminated with metal (given that the source of contamination is unable to be avoided, as it contributed by one of your process step), then MD = CCP.

[Marco Stefano]

Hello All,

Been lurking for a while; here goes with a first post. I started looking at this thread and realised that the page numbers kept climbing with each page...

We went through a large corporate HACCP review with the advent of BRC v5, with the intention of getting a corporate view on CCPs. And looking at the range of views here, how easy do you think that was?

We regard our metal detection and rejection systems as CCPs; it is the proverbial cartoon boxing glove on a stick that whacks the product (or test piece) off the belt and into a locked bin that completes the critical control bit. Both bits have to work to make a working CCP.

And because metal detection comes after loads of magnets, none of the magnets is a CCP. Control points - yes, monitored frequently - yes, CCPs - no.

Hope that helps, Marco.

[Tony-C]

This topic has been running for over 5 years now. So can we decide once and for all whether metal detection is a monitoring activity or a CCP?

Metal Dection must be a CCP or why else would anybody have bought them?

Regards,

Tony

[Charles Chew]

Five years is a long time Simon. The forum has grown and we are still hanging around. I would like to take this subject a little further but before doing so, I would like to believe that there is no one specific answer to this question and nobody is wrong so long as they can EACH validate their OWN justification for the risk characterization status that is taken.

For example -

We regard our metal detection and rejection systems as CCPs; ...... And because metal detection comes after loads of magnets, none of the magnets is a CCP. Control points - yes, monitored frequently - yes, CCPs - no.

My opinion is that the process of Magnet trappings is a "KILL STEP" which makes the last Magnet a CCP while the presence of MD AFTER loads of Magnets is purely a validation process on the effectiveness of the Magnets hence an OPRP. (In this instance, I am arguing that the process of Magnet trappings are in place to justify this risk characterization as an eliminating process. However, where Magnets do not exist, MD becomes a risk preventative / reduction process which makes it a CCP)

I certainly would like to have all your comments on this approach that I am taking.

Regards
Charles Chew

[Simon]

I'm certainly not one for killing debate. This is still a hot topic and thanks to new members Akira and Marco for your recent input. Please do continue the discussion...

Five years is a long time Simon. The forum has grown and we are still hanging around. I would like to take this subject a little further but before doing so, I would like to believe that there is no one specific answer to this question and nobody is wrong so long as they can EACH validate their OWN justification for the risk characterization status that is taken.

For example -

My opinion is that the process of Magnet trappings is a "KILL STEP" which makes the last Magnet a CCP while the presence of MD AFTER loads of Magnets is purely a validation process on the effectiveness of the Magnets hence an OPRP. (In this instance, I am arguing that the process of Magnet trappings are in place to justify this risk characterization as an eliminating process. However, where Magnets do not exist, MD becomes a risk preventative / reduction process which makes it a CCP)

I certainly would like to have all your comments on this approach that I am taking.

Regards
Charles Chew

[FSSM]

Five years is a long time Simon. The forum has grown and we are still hanging around. I would like to take this subject a little further but before doing so, I would like to believe that there is no one specific answer to this question and nobody is wrong so long as they can EACH validate their OWN justification for the risk characterization status that is taken.

For example -

My opinion is that the process of Magnet trappings is a "KILL STEP" which makes the last Magnet a CCP while the presence of MD AFTER loads of Magnets is purely a validation process on the effectiveness of the Magnets hence an OPRP. (In this instance, I am arguing that the process of Magnet trappings are in place to justify this risk characterization as an eliminating process. However, where Magnets do not exist, MD becomes a risk preventative / reduction process which makes it a CCP)

I certainly would like to have all your comments on this approach that I am taking.

Regards
Charles Chew

Dear Charles Chew,

I totally agree with you, so the poll might have one more option, "Depends", there is no totally no or yes and this doesn´t mean subjectivity.

Regards,

FSSM

[Simon]

Dear Charles Chew,

I totally agree with you, so the poll might have one more option, "Depends", there is no totally no or yes and this doesn´t mean subjectivity.

Regards,

FSSM

Hey FSSM, I finally worked out why this topic has been so popular.