No consumer or FDA would accept a product full of 1 mm aluminum bearings either. The typical metal detector
can't pick them up so does that mean the plant has NO CCP for metal because the detector can't pick them up and they are unacceptable? No, it means 1 mm aluminum is an adulteration and a quality issue but it's still not a hazard reasonably likely to result in serious injury or death. Fortunately these days I'm doing liquid product through a 40 micron filter.
FDA HACCP Plan -
metal inclusion.PNG 96.51KB
It's always been a highly contentious topic on this Forum.
I suspect FDA unintentionally set themselves up due the results of their own statistics inasmuch as they conceptually had no desire to offer support for a haccp CL of 6mm. Hence the type of example attached above. The situation was retrieved from a rejection POV via the non-wholesome adulteration criterion as you mention.
Afaik no other country has since generated statistical data to match that of FDA or has officially endorsed the FDA's 7mm cut-off(?)
IMEX nominating the highest, consistently attainable, sensitivity setting on the MD as CL has always satisfied an auditor.
For products I have been involved with, none of the customers would accept a ferrous target of < 7mm.
@ Elisabeth,the answer to yr auditor's comment likely depends on the (Operational?) context which you attached to the 2 terms in OP ?
PS - some additional threads/file which may be of interest here -
Kraft metal detector CCP, critical limits.pdf 426.98KB
Edited by Charles.C, 13 August 2019 - 02:26 PM.