5 replies to this topic

[lorlandini]

We receive acidulants and preservatives for beverage production.

 

During our HA, we identified a physical hazard that must be controlled by the supplier.  This hazard would be metal fragments from the production of the items.

 

How do I note this in our HACCP plan?

 

Is receipt of COA's declaring that there are no foreign materials acceptable to show that the hazard is being controlled by the supplier?

 

Thanks

[Ivan Ivanov]

Dear lorlandini,

 

You cant have limit as "metal fragments". you should determine physical limits for this metal parts. Its not possible any metal detector or x-ray t oensure you "0" level.

Another is that only Declaration or some documents supplied from the supplier is not enough. You should think based on the hazard analysis and associated risks how often and in which way to verify this information which is declare from your supplier. 

You should consider these things on the step reception of raw matterials. 

it matters are you certified and especially against which standard you are certified. BRC require some more strict acctivities to the suppliers of raw matterials and packaging matterials which are in contact with the food based on the special risk assessment according listed parametters. 

I hope that i am help you and now is more clear for youwhat should be done. :)

 

Best regards,

Ivan

[pHruit]

We receive acidulants and preservatives for beverage production.

 

During our HA, we identified a physical hazard that must be controlled by the supplier.  This hazard would be metal fragments from the production of the items.

 

How do I note this in our HACCP plan?

 

Is receipt of COA's declaring that there are no foreign materials acceptable to show that the hazard is being controlled by the supplier?

 

Thanks

 

If you require it to be in place for your HACCP plan / proces to allow you to make safe food, then this should surely be part of your prerequisite program?
I'd put this under supplier approval, as you perhaps need to be verifying that the suppliers have appropriate control before you decide whether they're suitable for use as suppliers - by the time you've purchased it and had it delivered to your site it's possibly a bit late to be determining this.

What information do you know about your suppliers? Are they certified to a GFSI-benchmarked standard? If so, it's a reasonable certainty that their foreign body controls will have been covered during their audits for this.
It should then be a fairly simple case of asking them to send a CCP summary or similar showing the critical limits and check frequencies for metal detection, sieving or whatever equivalent controls they're using for physical hazards, as this will allow you to confirm that their view of a hazard matches your system requirement (if you've decided that metal with a dimension e.g. >2mm is a hazard then it's not helpful if your suppliers' limit is e.g. 5mm).

If you're happy with the controls you've seen as part of your supplier approval process and specifically felt the need to get confirmation on a per-delivery basis then you could potentially ask the supplier(s) to include a statement on the CofA/CofC that the product has been sieved/metal detected in accordance with the agreed limits of ...mm.

[Scampi]

how exactly did you determine metal in an incoming ingredients was a hazard?  Have you been to their facility?  Did they tell you that?

 

It appears to me like this is a HA gone a little wonky

 

This should be covered by your approved supplier and separate from the HA. If you've determined you have metal coming in your raw materials YOU need to address it. 

Edited by Scampi, 16 January 2019 - 05:45 PM.

[lorlandini]

how exactly did you determine metal in an incoming ingredients was a hazard?  Have you been to their facility?  Did they tell you that?

 

It appears to me like this is a HA gone a little wonky

 

This should be covered by your approved supplier and separate from the HA. If you've determined you have metal coming in your raw materials YOU need to address it. 

Scampi,

 

We have an approved supplier program.  We had a GMP audit, where the auditor stated that we must show a documented hazard analysis on all of our ingredients, and acidulants was one ingredient that was highlighted as a potential metal fragment hazard from the processing.   My argument at the time was that our PRP, approved supplier program, was sufficient to ensure that we are receiving safe ingredients from our reputable suppliers.

[Scampi]

I agree with you completely. It is unheard of to receive an ingredient that has been completely processed and then say, but wait, it could have metal

 

We uses literally 100's of gallons of vinegar a year and I would not ever list this as a possible hazard. The very process of making liquid acidulants generally is with a still of some sort and filters........so I'm having a hard time understanding where you determine that these products could contain metal?

 

Yes, the HA should always been done on every incoming ingredient, but you can't then determine a hazard AT RECEIVING and then push it back a step to the manufacturer...........just remove this from your HA

 

A basic GMP auditors should not be telling you your HA isn't good enough...........GMP good manufacturing practices...........not the same as HACCP or a GFSI

 

Now granted, there are some ingredients that may have foreign material---field veg, pulses and grains.......but that is different than a manufactured item such as in your case.  Have another look at the anylisis......you just simply cannot say an ingredient has a known hazard risk and then not deal with it in house