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#1 StoneMill

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Posted 06 August 2018 - 03:46 PM

Hello,

 

HACCP plan I have inherited needs updating for CCPs.

 

We are a whole grain flour mill. No metal detection at this time. Current HACCP plan has CCPs-  labeling for allergens, and Hand washing for the introduction of more pathogens (since pathogens are inherent in raw material and our product which has not been subjected to a kill step). I want to remove hand washing as it is in our GMPs and kill step is passed on to customer via warning.

 

Needing a CCP at the last possible point I have decided to skip our rare earth magnets as a CCP and focus on the sifter screens which come after magnets in process/flow. We have implemented pre-operational check of sifter screens (screens, sifter basin and bolt count) at the beginning of every shift, every production run and after every 2,000 lbs of grain milled during large runs.

 

I know that metal detection is the way to go, but since we do not have this in place would the sifter screens be a legitimate CCP with the pre-op checks and mid run checks?

 

I have put our rare earth magnets on the pre-op check and daily or post shift cleaning schedule. However I have not considered listing this as a CCP since it is upstream from sifter screens.

 

Any suggestion on how to make this work and if this can be a trusted CCP is greatly appreciated.

 

Thank you.



#2 Scampi

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Posted 06 August 2018 - 03:57 PM

um...that's a tricky one

 

In a perfect world the magnet would be the very last step before packaging.....seems redundant to me to have it anywhere else......it can't be moved? 

 

You're really going to stop production every 2000 lbs to check the screens?  How likely is it that that will actually happen?

 

However, your checks seem reasonable to me IF your producing for further processed only, if your not, then you really need to move the magnet(s)  Do you know why they were put ahead of more metal risks?

 

The screens should still be inspected at pre op and post op/before sanitation either way


Because we always have is never an appropriate response!


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#3 lentilheather

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Posted 06 August 2018 - 04:37 PM

We process grains but don't mill them. We check all of our equipment including screens every day before operation and check the rare earth magnet every 10,000 pounds, it is the last thing our grain goes through before going into super-sacks. I believe checking it every 2,000 pounds would be extremely inefficient and likely that it wouldn't get done due to the hassle. Moving the magnet would make the process easier and safer. How do you know that a nut or bolt didn't come loose on your equipment after  the rare earth magent and is now in your flour. 



#4 FSQA

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Posted 06 August 2018 - 05:14 PM

Moving the magnet would make the process easier and safer. How do you know that a nut or bolt didn't come loose on your equipment after  the rare earth magent and is now in your flour. 

 

Rightly said.... besides the nut or bolt, (potential )Metal shavings-Post screens from the unit is a hazard itself and difficult to detect post-processing.



#5 lentilheather

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Posted 06 August 2018 - 05:38 PM

Another thought is that you could leave the magnet where it is and add another magnet at the end of the line. That way you know metal isn't going into your sifters & screens and if metal inclusion occurred after the first magnet you would have a smaller area to trace where it came from. 



#6 StoneMill

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Posted 06 August 2018 - 06:28 PM

Hi Scampi,

 

Thanks for responding so quickly. This does seem tricky.

 

The system(s) in place do need some improvements. All magnets on our mills are set at the beginning of our systems (before milling). The size and shape of magnets prohibit them from being placed or installed in another location without major work. At this point I wold suggest purchasing magnets more specific in size/shape for the location. In short, the magnets we have now can't be moved successfully.

 

Our 2,000 lb check happens daily on 3 mill systems. Average 3 times per shift. We have had some issues with hardware on our sifter screens coming loose. So far we have not lost any hardware but since we do not have magnets after our sifter screens or metal detection it was decided that we needed to check regularly to ensure our products are safe. This arose out of a run of 8,000 lbs which potentially had a foreign object in it. We would have had to sift through all 8,000 lbs. since we could not narrow time of deviation. We decided that if we checked every 2,000 pounds we would at least narrow our search should we have an incident. It is a terrible interruption to production but without any other safety measures (CCPs) do we have a choice? I am open to suggestions!!!

 

From what I understand, when the company started it was suggested that rare earth magnets be used in our milling systems. There was no further consultation on the proper location for the magnets. Asize found online fit the mill inlet perfectly and that was it. 

 

Thanks for your input. I appreciate it.



#7 StoneMill

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Posted 06 August 2018 - 06:50 PM

Lentilheather & FSQA, 

 

Preach it! The 2,000 lb. check was a temporary solution while I've tried to clarify and justify the request for new magnets in proper location and/or metal detection. The suggestion of this check was necessary due to the threat of losing hardware. I know this check is extremely inefficient and troublesome as I am out on the floor to help and make sure it gets done. I just didn't know what else to do to make sure we weren't losing hardware in the meantime. However this check does not protect against metal shavings which is a good point for me to make as I request the additional magnets/metal detection. So thank you both!!

 

My idea is to keep the magnets before milling in place and add magnets at the end of the system as you pointed out. Thank you all for your input. I believe I have what I need to make my case for acquiring the proper equipment which will answer my CCP questions.

 

Much appreciated!!!! 



#8 012117

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Posted 07 August 2018 - 01:24 AM

Hi, Stonemill.

 

Just to add to the above that you may want to reconsider.

 

If the sifter installed the magnetizable type? During your hazard assessment, on top of the sifter that you installed, have you identified any other magnetizable metal that can be caught by the magnet if you install it after the sifter? If the sifter is not magnetizable and no other magnetizable hazard is identified, would it still be logical to install magnet after the sifter?

 

From your magnet collection, what do you usually collect after 10000 Kg? Understanding from above, there seem to be difficulty in sifter inspection for every 2000kg. You may want to balance the frequency of inspection for your sifter based on the hazard analysis you conducted and the historical trend your magnet provides (this is considering as well that magnet is validated in terms of proper strength, the flow of the product is not that strong enough to remove any physical hazard already adhering in the magnet, the distance between magnet rods and its housing, etc.)

 

If confidence is low and we worry about the 8000 Kg, it is more worthwhile to consider improving where this foreign material usually came from instead of considering to add magnet after the sifter? 



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#9 Charles.C

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Posted 07 August 2018 - 03:12 AM

Is it really that much cheaper to add more magnets as compared to buying a metal detector ? And minimising auditorial explananations.

(assuming the pack size allows a realistic sensitivity).


Kind Regards,

 

Charles.C


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#10 StoneMill

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Posted 07 August 2018 - 07:43 PM

012117,

 

Thank you for input. 

 

The sifter screens are not magnetizable. This does raise question to magnetizing the hardware which fastens the screens. The magnets we have in place give a history of a minimal amount of metal in our grain as it is cleaned by supplier equipped with magnets. My concern is with the introduction of metal from the milling system (nuts/bolts from sifter screens, welds, and other hardware coming loose). 

 

The current check every 2,000 lbs. is temporary until I can find a solution. There have been issues with the hardware (nuts/bolts) becoming loose during runs and this is where I am concerned. We are not equipped as we should be.

 

The more I review the information presented here the more I see a definite need for the company to invest in metal detection.



#11 StoneMill

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Posted 07 August 2018 - 07:48 PM

Charles C.

 

After starting this topic I met with the owner and management and spelled out the issue. I was just handed research and quotes on metal detection. I appreciate everyone's input here as it has given me the information and confidence to push in the right direction. The corrective action helped as well.

 

Spending the money to ensure we produce safe products is a valuable investment. Thanks for helping me make the point.



#12 Abd El-Rahman

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Posted 19 December 2018 - 11:40 AM

i think magnet must be put before package direct after control sifter 

sifter and this magnet is a CCP

 

 





Also tagged with one or more of these keywords: HACCP plan, CCP, critical control point, foreign material, sifter screens, food safety, FSMA, verification, flour mill, grains

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