You should re visit your hazard analysis.
Having been in the bakery biz for 28 years, I have never had a CCP for a sieving process step.
If you have a 30 mesh screen on your flour sifter, you are not going to have any FM get through that would cause any type of foreign material problem.
You of course need to check the sifter on a regular basis to ensure that is intact, but as far as it being a CCP, that's overkill.
I mostly agree with you but, despite intuitive logics, there are many cases documented in this Forum where sieves are set as CCP steps (maybe not in USA). Including a few in Baking Industry (may often be due to customers/auditors !)
As per yr Post, and to answer the OP, the typical (but not unique) response for CL is to use integrity of screen.
Offhand, I wonder if in current case, the sieve will be the only CCP = haccp "pragmatism" in lieu of a metal detector.
Just for illustrations, ex Kraft manual -
3.3 Physical: Extraneous Matter
Pieces of glass, metal, hard plastic, etc. are potential physical hazards. Extraneous matter does not usually present a significant risk of a severe adverse health effect, potentially causing only minor injuries. Extraneous matter is best controlled by Prerequisite Programs such as supplier selection and approval, preventative maintenance, etc. However, in some cases, the characteristics (size, shape and type) of the extraneous matter may potentially cause serious harm. On that basis, some extraneous management controls including detection/removal devices may be managed as CCPs.
In general, extraneous matter is defined as any object/material that may become part of the product being produced that is not designed to be a part of such product. Relative to HACCP, extraneous matter pertains to objects that may potentially cause serious harm during consumption of the product. Typically these objects will be hard or sharp.
3.3.2 Management as a CCP or PP
When the Hazard Evaluation Flow Chart identifies the need to control the potential physical hazard posed by extraneous matter in HACCP, the following criteria establishes the CCP(s) or PP(s):
- The PP for glass packaging is the clean-up of glass (following a breakage incident), post filling (or after the glass cleaner/inverter), prior to package capping, if a detection/removal device for
glass is not on the line. The inspection of the cleaning process must be documented. In addition, glass filling lines must have covered conveyors over exposed open jars after the jar
cleaner/inverter (prior to filling and capping) to minimize potential for extraneous glass falling into an open jar.
- An extraneous detection/removal device that is present on a line/process is a CCP if its primary purpose is to prevent, eliminate, or reduce hazardous extraneous matter in the product and it is the last and/or most effective extraneous detection/removal device on that line/process.
- In some cases, more than one extraneous detection/removal device on a line/process may be managed as a CCP if the devices are effective for removing different types of extraneous matter
- Extraneous removal/detection devices may include:
CCP,CL etc for in-line filter-screen-sifter-sieve.pdf 200.11KB
(a few "x"s are mentioned in previous threads on this topic)