199 replies to this topic

[GMO]

Oh this thread is too long to go back and read what I said before... but in the codex decision tree the fact it asks:

"Is the step specifically designed to eliminate or reduce the likely occurance of a hazard to an acceptable level?"

I can't see how the answer to this question can ever be "no" to metal detection. I mean I suppose you could say it's monitoring metal contamination but the fact is it also removes it; that's what it's designed to do.

[mesophile]

Hi,

There are pro's and con's with metal detection being a CCP.

I would ALWAYS ALWAYS ALWAYS go with metal detection as being a CCP when it is at the final stage of the production process.

It has been requested by the Retailers and a vast range of auditors.

Save yourself lots of ear bashing and conflict and just do it.

Regards

Simon

[GMO]

Hi,

There are pro's and con's with metal detection being a CCP.

I would ALWAYS ALWAYS ALWAYS go with metal detection as being a CCP when it is at the final stage of the production process.

It has been requested by the Retailers and a vast range of auditors.

Save yourself lots of ear bashing and conflict and just do it.

Regards

Simon

^^^^^ Totally. Why fight a war? Accept it, it is not going to make it any less safe.

[StuartMarriott]

For me this is quite simple (from a point of view of primary production)...

Whilst I agree with the sentiment of a metal detector not altering or affecting the product, why do we even have them on our sites? if not for minimising the risk of product contaminated with metal (above and beyond threshold limits, granted) going to the market!

Once they're on site, the decision tree - 'step specifically deigned to reduce or control hazard...' - does the rest

CCP it is for me...

[DP2006]

Hi Everybody,

When I saw this topic, I thought "great, sound interesting" but when I saw it goes on for 11 pages (and counting? ) I lost the will to live and read through all of the content.

I know I might be missing some real gems of information but that's my loss.

I took part in another related thread Metal Detectors - Determining Critical Limits

From this you get the distinct impression that metal detection is not an exact science due to the variables that can have an effect.

On this basis, I like the argument that Metal Detection is a control point and not a CCP. In terms of this thread I would therefore vote for "Monitoring Point".

However, I also fully agree with the Codex Decision tree approach which would indeed determine that metal detection is indeed a CCP and I might therefore vote for that option.

Unless anyone else has mentioned it (in the previous 10 or is it 11 pages ) at the risk of stirring up a hornets nest, you could also propose that metal detection be classified as (that ISO22000 old chestnut) an Operational Pre-Requisite Programme (OPRP).

I admit this is a "cop out" but as an OPRP it elevates above the standard of a control point but stops short of having it as a CCP.

However, going back to the thread on determining metal detector critical limits and considering the "black art" of metal detection, for me by all means have this as a CCP but ensure you focus on other PRPs and OPRPs that minimize the risk of metal ever reaching the final metal detector eg supplier assurance, tool accountability, personal items etc.

Good Luck!

DP2006

[Harish R]

It should be considered as a CCP if it comes after the packaging step

[GMO]

From this you get the distinct impression that metal detection is not an exact science due to the variables that can have an effect.
Unless anyone else has mentioned it (in the previous 10 or is it 11 pages ) at the risk of stirring up a hornets nest, you could also propose that metal detection be classified as (that ISO22000 old chestnut) an Operational Pre-Requisite Programme (OPRP).

I admit this is a "cop out" but as an OPRP it elevates above the standard of a control point but stops short of having it as a CCP.

 

 

I've said it before and I'll say it again... oPRPs are for people who can't make up their minds! 

[Charles.C]

I've said it before and I'll say it again... oPRPs are for people who can't make up their minds! 

 

Dear GMO,

 

Or perhaps a Risk Probability where 30% < P < 70%.

 

Which probably comes to the same thing so  >>> Toss a Coin ? Get a second +  opinion ? Be conservative ?

 

Maybe Football has a better approach, points accrued, goal difference, head-to-head

 

Pathogen Micro-testing kits also run into the same biochemical problem IMEX, choice of criteria, choice of weighting, choice of probability level for >  decision.

 

As you say, OPRP represents the flexible grey area, i ofter wonder how people consistently validate its "safety achievance" level which is seemingly required to be equivalent to a CCP but without using critical limits.

 

Rgds / Charles.C

[lmarquez]

Hello,

 

i have gone thru various GFSI,GMP,FSA,FSIS, audits and none have gave us a non conformance for not having metal detectors as a CCP. We simply explain how due to the low number of foreign contamination, risk assesments, inspections throught the process and preventive maintenance program we consider metal detectors a CP.

 

We currently process Ready to eat products.

[Charles.C]

Dear Luis Miguel,

 

Congratulations !

 

Does this mean you have no CCPs, ie no haccp plan ?

 

You don't produce  apples by any chance ?

 

BTW, AFAIK, a "GFSI" audit does not exist (yet).

 

Rgds / Charles.C

[DavidAR]

Hi 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

Was just reading through this thread and picked out this quote to use a reference point.

 

It always gets my head spinning when I think about what our suppliers do with their products and then what our customers do with ours.. is a metal detector always a CCP??? absolutely not...maybe LOL

 

Example: If I produce cardboard cases to a food manufacturer then would  a MD CCP be required? for our internal HACCP system maybe, maybe not the risk of metal bolts,washers etc going in to flat packed cases is marginal at best perhaps in the base materials or cardboard making I don't know... The point im making is this.. no matter the metal content in the box the food end user WILL have a metal detector for sure because of there haccp system identifying metal being bad for consumer health, fit for purpose and all that...But like my next example maybe it should be a GMP CP?

 

I worked at a site who slauhgtered pigs etc they had a metal detector but it was only a control point as a matter of GMP their haccp decided that nobody could get hurt from their product as it was being supplied to a business whos role was to process the carcase in to other smaller products/packaged for consumer and at that end point would be re metal detected as a CCP. they did how ever as a I say used metal detection as a control point anyways even though they did not really feel they needed it...so I was explained.

[Tony-C]

I worked at a site who slauhgtered pigs etc they had a metal detector but it was only a control point as a matter of GMP their haccp decided that nobody could get hurt from their product as it was being supplied to a business whos role was to process the carcase in to other smaller products/packaged for consumer and at that end point would be re metal detected as a CCP. they did how ever as a I say used metal detection as a control point anyways even though they did not really feel they needed it...so I was explained.

 

Does sound a bit like head in the sand job 'the next guys going to sort it out if we put some metal in it!'

 

Perhaps this was in combination with other GMPs such as blade/knife logs and inspection so they decided it wasn't critical.

 

Anyway I would be less than impressed if I received a piece of metal in a product because someone knew I had a metal detector!

 

Regards,

 

Tony

[Bean Queen]

Location in the process determines whether or not it is a CCP, you know beginning or end... sometimes it is and sometimes its not. lol.

[fgjuadi]

 

Anyway I would be less than impressed if I received a piece of metal in a product because someone knew I had a metal detector!

 

Regards,

 

Tony

This is hilarious

[BrionacVII]

With the ccp you eliminate/Decrease a hazard which, if not detect now, subsequently you may not detect or remove it.

 

So this is a CCP.

[TAN85]

Hi there, I'm new to a this so adding my 2 cents to see if I'm catching on to the correct systems and interpretations. (Also, I'm a few years behind on this post haha, but hoping to still get feedback)....

 

To use my auditor's explanation, anything that is a PRP is not a CCP.  I would classify metal detection, along with all the monitoring and calibration etc that goes with it, a PRP. That said, I think it would also depend on the type of industry .... i.e. RTE food producers would definitely need this step as the lack thereof would result in a "potentially hazardous situation" (which I have as the definition of a CCP). Also, the Control Limits for metal detection would not entirely be a measurable range - it would simply be present or absent. There is no room to determine what amount of metal detected would be "acceptable" (obviously). In conclusion, it is not a process that serves to control, nor does it eliminate (it merely detects, the act of controlling would be a previous process and eliminating would be the next process), and by this reasoning, I do not think it classifies as a CCP.

[AllisonB]

At my company, we monitor for metal but it is not a CCP for us. We use a screen to filter out foreign material - this is our CCP at this stage, because we are concerned for about more than just metal fragments. 

 

But I agree with the others, a CCP is something that can be customized to your type of production, and to what makes sense with your HACCP plan. If it is appropriate that metal detection is a CCP, or not, then you have to have the right stuff to back it up, either way you go.

 

-A 

[ncwingnut]

We have metal detection in our powder packing process, but it's not a CCP, it's a QCP.  The only CCPs that we have are the sifters before the metal detector.  We also use rare earth magnets that are also a QCP.  

[it_rains_inside]

Thought Id throw my 2 cents in:

 

We use metal control as an monitoring practice. Not as a CCP - we are BRC certified and have never had an auditor even blink twice at it - BECAUSE - we use screens (post-magnet) that are the CCP at that step.

 

It is dependent on your product and your HACCP plan and the total hazards trying to be avoided. If you are minimizing the risk of any other foreign material that is non-metallic, then metal control is not sufficient as a CCP. This question is almost taken out of context, when you really think about it.  When asked with the full background, the full scope of hazards, the process, the hazard reduction necessity, and placement of such. The answer could wildly vary.  

Its all subjective anyway 

[jel]

Recordando: Un PCC es una etapa en la que se puede aplicar un control, y que es es esencial para prevenir o eliminar un peligro relacionado a la inocuidad de los alimentos, o para reducirlo a un nivel aceptable.

 

Por otro lado, el monitoreo es la secuencia planificada de observaciones o mediciones para evaluar si las medidas de control están funcionando.

 

Ambas definiciones son de ISO 22000.

 

El PCC es una medida de control que se implanta para el control de peligros de riesgo alto, la cual tiene que estarse monitoreando para verificar que está trabajando.

 

Es decir, la pregunta de si la detección de metales es una actividad de monitoreo o un CCP, no tiene razón de ser, ya que no puede existir un PCC al que no se le realizan actividades de monitoreo

 

[Dharmadi Sadeli Putra]

Recordando: Un PCC es una etapa en la que se puede aplicar un control, y que es es esencial para prevenir o eliminar un peligro relacionado a la inocuidad de los alimentos, o para reducirlo a un nivel aceptable.

 

Por otro lado, el monitoreo es la secuencia planificada de observaciones o mediciones para evaluar si las medidas de control están funcionando.

 

Ambas definiciones son de ISO 22000.

 

El PCC es una medida de control que se implanta para el control de peligros de riesgo alto, la cual tiene que estarse monitoreando para verificar que está trabajando.

 

Es decir, la pregunta de si la detección de metales es una actividad de monitoreo o un CCP, no tiene razón de ser, ya que no puede existir un PCC al que no se le realizan actividades de monitoreo

Anybody can help me to translate this in english ?

Gracias Amigo

[Simon]

Anybody can help me to translate this in english ?

Gracias Amigo

 

 

Remembering: A PCC is a stage at which control can be applied and is essential to prevent or eliminate a hazard related to food safety, or reduce it to an acceptable level.

 

On the other hand, monitoring is planned sequence of observations or measurements to assess whether control measures are working.

 

Both definitions are ISO 22000.

 

The PCC is a control measure that is implanted to control high-risk hazards, which must estarse monitoring to verify that it is working.

 

That is, the question of whether metal detecting is an activity monitoring or CCP, has no reason to be, since you can not be a PCC that is not engaged in monitoring

[jel]

Anybody can help me to translate this in english ?

Gracias Amigo

Excuse me, I'm from México and my english isn't very good, but using google's translate:

 

Remembering: A PCC is a stage at which control can be applied and is essential to prevent or eliminate a hazard related to food safety, or reduce it to an acceptable level. 

 

On the other hand, monitoring is planned sequence of observations or measurements to assess whether control measures are working. 

 

Both definitions are ISO 22000. 

 

The PCC is a control measure that is implanted to control high-risk hazards, which must be monitoring to verify that it is working. 

 

That is, the question of whether metal detecting is an activity monitoring or CCP, has no reason to be, since you can not be a PCC that is not engaged in monitoring

[gaardendan]

The Canadian Food Inspection Agency has added a section to it's pre-requisite programs (see Food Safety Enhancement Program FSEP Manual). I could be mistaken but it looks like they are giving Candian facilities a way to reclass all foreign material CCP's as PP's.

 

 

 

 

 

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:
> a list of foreign material detection and/or removal equipment used at the establishment where applicable, the sensitivity of detectors and best practices that
must be applied to reach this sensitivity (e.g. The nature of the food, sizes of food, packaging, location of equipment, speed of lines, potential environmental effects, etc.)
> where applicable, the mesh and/or gauge size of filters and sieves
> where applicable, the strength of magnets
> the names or titles of personnel responsible for ensuring that the equipment is working effectively
> the methods, instructions or procedures for tests or observations to be performed
> the frequency of the tests or observations to be performed
> the corrective actions to be taken on the equipment and on the product when the equipment is not working effectively*
> the record(s) to be completed
>
> The program shall also include procedures to follow when products are rejected by detection systems or when foreign materials are removed by removal systems. The procedures include but are not limited to:

> controls/mechanisms in place to ensure that the rejected product is effectively segregated and managed
> the names or titles of personnel responsible for examining any rejected products or removed foreign materials, investigating the cause of the
> rejection and the presence of foreign material, and applying corrective measures** methods or instructions for examination of rejected products the record(s) to be completed.
>
> *when a detector is discovered not to be working during a test, the corrective actions must include a combination of segregation and re-inspection of all products that have passed through the detector since it was last tested to be working. Where defective filters, sieves or magnets are identified, the potential for contamination of products shall be investigated and appropriate actions taken.
>
> ** including analysis of the results of the investigation performed on rejected product to determine if trends exist (i.e.: multiple false
> rejections) that may suggest an error with the detector or indicate that the settings are too sensitive for a particular product and require
> adjustment.
>
> Note: calibration and maintenance of equipment used to detect and/or remove
> foreign materials are covered under 3.1.1.3 - c.1.2 equipment maintenance
> and calibration.

[mamad123]

Hi,

 

I think CCP should be addressed to "STEP" which means a part of "Process Step". if metal detection is considered as a part of process step in HACCP manual(not monitoring), then it might be considered as a CCP. remember, Establishing Process step is necessary prior to Determining hazard.

 

correct me if I am wrong, that argument is not 100% valid