Jump to content

  • Quick Navigation
Photo
* * * * - 3 votes

Metal Detection - is it a Monitoring Activity or a CCP?

metal detection

  • You cannot start a new topic
  • Please log in to reply
186 replies to this topic

Poll: Is Metal Detection? (509 member(s) have cast votes)

Is Metal Detection a Monitoring Activity or a CCP?

  1. A Monitoring Activity (152 votes [29.86%])

    Percentage of vote: 29.86%

  2. A Critical Control Point (CCP) (357 votes [70.14%])

    Percentage of vote: 70.14%

Vote Guests cannot vote

#176 Philip Jones

Philip Jones

    Grade - AIFSQN

  • IFSQN Associate
  • 37 posts
  • 11 thanks
4
Neutral

  • United Kingdom
    United Kingdom
  • Gender:Male

Posted 13 November 2018 - 09:37 PM

Goodness me. Is this thread still going?

This is like a Brexit question, splitting the decision as to CCP or not.  Who is telling the truth, who is not?
 

Having looked through the comments, people have debated the academic side of this rather than the practicalities.

 

Let me give you a scenario.

A laundry uses pins in supplied laundered protective clothing. We have no alternative (not acceptable, I know, but bear with me, this is a thought exercise). 

HACCP team reviews this and decides that despite requirements that pins are removed, there is still a risk, but we have a critical control point metal detector set at 3mm stainless.  We all know that a pin in the "correct" orientation can pass through a fully functioning and correctly calibrated metal detector, so, despite the CCP status, we are not making the food safe.  This pushes the critical control point back to clothing inspection at intake a new CCP.  Everybody happy with that? Of course not.  Even if you triple passed the garments through a different metal detector, I doubt any technical person would make that offline detector a CCP, it would be a PRP (or OPRP).

We therefore have an in-line metal detection step that can't function achieve the CCP requirements of guaranteeing safe product and a completely separate metal detector that wouldn't be made a CCP despite it being a better control than the online unit.

 

Another practical element to this conundrum (but real life this time).

We have a bearing starting to break up and it is putting small fragments of sharp metal into the product flow.  Too small to be rejected, they unfortunately go out with product. The pieces get larger until eventually one is rejected and found. Unfortunately we still have no idea where it has come from, despite investigations, and production continues with more small pieces being released (unknowingly) to the consumer. Eventually after a couple more rejections, we find the source.

The metal detector has has allowed us to identify the source but has not prevented potentially unsafe product being despatched.

Does this really sound like a CCP or is the metal detector being used as a monitor (particularly in the days or weeks following the incident)?

 

To me, both scenarios sound like a monitoring exercise. 

I know big pieces would be picked up and rejected, but making a product safe under certain circumstances doesn't make the operation a CCP.  Having a metal detector doesn't make a product safe under all circumstances, few circumstances do, (such as achieving a particular Fo value in thermal processing). 

 

All that off my chest, at the end of the day, if you call it a CCP or an OPRP, the steps you take, the controls you have in place are probably the same anyway. Just remember that the responsibility is to make safe food not to argue whether controls are effective or not effective depending on the heading on the instruction sheet.



#177 Simon

Simon

    Grade - FIFSQN

  • IFSQN Admin
  • 11,884 posts
  • 1197 thanks
385
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:Manchester
  • Interests:Life, Family, Running, Cycling, Manager of a Football Team, Work, Watching Sport, The Internet, Food, Real Ale and Sleeping...

Posted 15 January 2019 - 02:46 PM

Goodness me. Is this thread still going?

This is like a Brexit question, splitting the decision as to CCP or not.  Who is telling the truth, who is not?
 

Having looked through the comments, people have debated the academic side of this rather than the practicalities.

 

Let me give you a scenario.

A laundry uses pins in supplied laundered protective clothing. We have no alternative (not acceptable, I know, but bear with me, this is a thought exercise). 

HACCP team reviews this and decides that despite requirements that pins are removed, there is still a risk, but we have a critical control point metal detector set at 3mm stainless.  We all know that a pin in the "correct" orientation can pass through a fully functioning and correctly calibrated metal detector, so, despite the CCP status, we are not making the food safe.  This pushes the critical control point back to clothing inspection at intake a new CCP.  Everybody happy with that? Of course not.  Even if you triple passed the garments through a different metal detector, I doubt any technical person would make that offline detector a CCP, it would be a PRP (or OPRP).

We therefore have an in-line metal detection step that can't function achieve the CCP requirements of guaranteeing safe product and a completely separate metal detector that wouldn't be made a CCP despite it being a better control than the online unit.

 

Another practical element to this conundrum (but real life this time).

We have a bearing starting to break up and it is putting small fragments of sharp metal into the product flow.  Too small to be rejected, they unfortunately go out with product. The pieces get larger until eventually one is rejected and found. Unfortunately we still have no idea where it has come from, despite investigations, and production continues with more small pieces being released (unknowingly) to the consumer. Eventually after a couple more rejections, we find the source.

The metal detector has has allowed us to identify the source but has not prevented potentially unsafe product being despatched.

Does this really sound like a CCP or is the metal detector being used as a monitor (particularly in the days or weeks following the incident)?

 

To me, both scenarios sound like a monitoring exercise. 

I know big pieces would be picked up and rejected, but making a product safe under certain circumstances doesn't make the operation a CCP.  Having a metal detector doesn't make a product safe under all circumstances, few circumstances do, (such as achieving a particular Fo value in thermal processing). 

 

All that off my chest, at the end of the day, if you call it a CCP or an OPRP, the steps you take, the controls you have in place are probably the same anyway. Just remember that the responsibility is to make safe food not to argue whether controls are effective or not effective depending on the heading on the instruction sheet.

 

Good points, well made Philip, so I guess the answer is it may or may not be a CCP depending on the circumstances.

Therefore everybody is right...and it is time for us to come together.  Just like Brexit. :smile:

 

Regards,

Simon


Best Regards,

Simon Timperley
IFSQN Administrator
 
hand-pointing-down.gif

Need food safety advice?
Relax, you've come to the right place…

The IFSQN is a helpful network of volunteers providing answers and support. Check out the forums and get free advice from the experts on food safety management systems and a wide range of food safety topics.

 
We could make a huge list of rules, terms and conditions, but you probably wouldn’t read them.

All that we ask is that you observe the following:


1. No spam, profanity, pornography, trolling or personal attacks

2. Topics and posts should be “on topic” and related to site content
3. No (unpaid) advertising
4. You may have one account on the board at any one time
5. Enjoy your stay!


#178 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 15,726 posts
  • 4323 thanks
707
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 15 January 2019 - 04:09 PM

Hi Philip,

 

Just to note that HACCP has never claimed to guarantee zero risk.

 

Hence CCP defining words like "acceptable" and for FSMA  "significantly minimize".

 

Subjectivity Rules ! :smile:


Kind Regards,

 

Charles.C


#179 PollyKBD

PollyKBD

    Grade - AIFSQN

  • IFSQN Associate
  • 44 posts
  • 4 thanks
10
Good

  • United States
    United States

Posted 15 January 2019 - 06:49 PM

Thanks Charles - Flattery will get you everywhere french_cig.gif

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

We recently received packaging with a screw in it that had fallen out of the equipment used producing the packaging. We found it in a container during one of our packaging runs. The packaging company added checking the tightness of bolts prior to production and accounting for all the bolts after production to their procedures after this incident. Not really an argument for or against. Just a story about something that happened. 



#180 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 15,726 posts
  • 4323 thanks
707
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 16 January 2019 - 01:48 AM

We recently received packaging with a screw in it that had fallen out of the equipment used producing the packaging. We found it in a container during one of our packaging runs. The packaging company added checking the tightness of bolts prior to production and accounting for all the bolts after production to their procedures after this incident. Not really an argument for or against. Just a story about something that happened. 

 

It's an argument as to the difficulty in preventing human error. Probability of Failure  = 1.0. Frequency = ?


Kind Regards,

 

Charles.C


#181 Manish Semwal

Manish Semwal

    Grade - Active

  • IFSQN Active
  • 12 posts
  • 0 thanks
0
Neutral

  • India
    India

Posted 16 January 2019 - 12:39 PM

Hi guys,

First of all I must say this was really a good question picked with great logical intended approaches and inputs by all..

 

What I figure out about CCP in case of metal detector is Hazard severity i.e. Metal, now we all should  have consensus on this, that a metal is a Food safety hazard and has a great potential to put the food in completely unsafe condition as this could harm the consumer badly..going forward you are putting the Metal detector as an control measure which does reduces the hazard in terms of sensitivity like 1.5 mm for Ferrous in maximum food industry's (As less than 1.5mm could pass the CCP but risk level becomes low) and eliminates the same by rejecting the particular contaminated part.

 

The concept is to release the safe food only and this is sufficed by doing so, and this demands an monitoring activity at much stringent parameter without any short fall or negligence.

 

As Charles said above that if something changes the shape or formulation of the product becomes CCP, is not the perception here but elimination of food safety hazard from the process flow Is, through any activity or equipment.

 

Regards :smile:



#182 antond

antond

    Grade - Active

  • IFSQN Active
  • 8 posts
  • 0 thanks
0
Neutral

  • United States
    United States

Posted 16 January 2019 - 03:29 PM

These are all excellent points! 

 

In reply to those who said we don't have identified risks and only look at our raw materials, this is false. We do look at our equipment and history issues which are virtually none in regards to metal fragments. The issue I with it as a CCP in our company is because we have one building that is a WET operation where we make paste products and one building that is a DRY operation which is all powders. Our HACCP plan is very similar in both instances in regards to the process and the products that we use; however, for some reason we deem Metal Detection as a CCP on the DRY side. When I first started working here, they told me that they do not metal detect on the WET side unless it is a customer requirement because it's not as easy to put our products through. On the DRY side, all products already packaged through a screen and filter are ran through a stand a lone metal detector. So I get asked the question, why would you have metal detection as a CCP on the DRY side and not the WET side. That is why I am looking for arguements to reduce down from a CCP. 

 

I'm from the  younger generation that wants to change from the midset of "BRC told us we had to have a CCP so that's why we have it". People don't like change so I need a strong argument to support. 

 

The definition is to reduce or eliminate, to be honest, there has not been a SINGLE instance in the past 5 years of our metal detector going off and us actually finding something. It usually ends up being something wrong with our boxes. 

 

This topic usually makes my head spin! 



#183 Scampi

Scampi

    Fellow

  • IFSQN Fellow
  • 2,829 posts
  • 772 thanks
334
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 16 January 2019 - 04:42 PM

It's up to you to use the decision tree and determine if it is a CCP or not..............soooooooo in your case, use the decision tree and see what shakes out

 

http://www.inspectio...035?chap=4#s8c4

 

above is a link to a CCP decision tree..............I don't like risk assessments, too subject......decision tree use facts (you must list the other programs that control the hazards)


Because we always have is never an appropriate response!


#184 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 15,726 posts
  • 4323 thanks
707
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 17 January 2019 - 02:01 AM

I think all the usual Decision Trees are (or include) Risk Assessments ? Just concealed ones.

 

eg "Is it likely that .........

 

(The Canadian FSEP used to have a very nice Risk Matrix also).


Kind Regards,

 

Charles.C


#185 Scampi

Scampi

    Fellow

  • IFSQN Fellow
  • 2,829 posts
  • 772 thanks
334
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 15 February 2019 - 02:09 PM

Here's the link to the FSEP program in it's entirety. It has been archived as per the new SFCR but is still relevant.  (cannot find a risk matrix, nor do I remember ever seeing one from CFIA)

 

Regarding whether metal detection is a CCP or monitoring would depend completely on the use of the 12 HACCP steps.....without interpretation or bias (HAHAHAHA)

 

I personally feel that the HACCP waters have been muddied beyond recognition by GFSI to the point that everyone is dazed and confused and science has taken a back seat hence the age and length of this thread


Because we always have is never an appropriate response!


#186 Nassu

Nassu

    Grade - Active

  • IFSQN Active
  • 12 posts
  • 0 thanks
0
Neutral

  • South Africa
    South Africa

Posted 31 March 2019 - 10:28 PM

HI Guys

 

This is my first time actually using this platform.

 

I work for an edible oil industry where we pack oil in 10L bags and pass through the metal detector. It was identified as a CCP however during our Audit, the auditor questioned as to why it was a CCP. She looked at my hazard analysis from the start and through out the other process steps  prior to the metal detector - likelihood of any physical object including metal was low however it was a contradiction as at the metal detector process step the likelihood was identified as a high and then looking a the severity deemed it a significant risk and thereafter put through the CCP decision identified it a as a CCP but her view point made sense because the severity of metal in product is a critical  to the consumer but the likelihood of it being in the product is low and using the risk assessment table (depending on  which table is used) the risk was deemed  not critical  and therefore not a CCP- so it could just be a monitoring activity. I would not say an OPRP as it s measurable and it controlled by procedures and verification of testing at frequencies using different sensitivities/test pieces- so it is measurable  and controlled but I dont think it will fall under the category of a OPRP 

 

Regards

Nassu



#187 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 15,726 posts
  • 4323 thanks
707
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 06 April 2019 - 08:23 PM

HI Guys

 

This is my first time actually using this platform.

 

I work for an edible oil industry where we pack oil in 10L bags and pass through the metal detector. It was identified as a CCP however during our Audit, the auditor questioned as to why it was a CCP. She looked at my hazard analysis from the start and through out the other process steps  prior to the metal detector - likelihood of any physical object including metal was low however it was a contradiction as at the metal detector process step the likelihood was identified as a high and then looking a the severity deemed it a significant risk and thereafter put through the CCP decision identified it a as a CCP but her view point made sense because the severity of metal in product is a critical  to the consumer but the likelihood of it being in the product is low and using the risk assessment table (depending on  which table is used) the risk was deemed  not critical  and therefore not a CCP- so it could just be a monitoring activity. I would not say an OPRP as it s measurable and it controlled by procedures and verification of testing at frequencies using different sensitivities/test pieces- so it is measurable  and controlled but I dont think it will fall under the category of a OPRP 

 

Regards

Nassu

 

The typical traditional  haccp logic is simple. If you can justify that likelihood of occurrence is low, supports no need for a CCP..

 

But the justification is often contentious.

 

If the hazard analysis concludes no significant risk, it is IMO illogical to propose an OPRP.  However some of the various interpretations of OPRP may (and probably do) suggest otherwise.


Kind Regards,

 

Charles.C






0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate