5 replies to this topic

[jaycf7]

Good morning! 

 

We have only 2 CCP's, our metal detectors and labeling.  Recently we experienced our metal detector failing which shut us down, this brought up the question of is there a way to risk assess and re-look at our HACCP plan and build in a back up plan so that possibly our magnets were CCP's as well in the event of the metal detector being out of service.

 

My thought is that our main food saftey concern is metal in the final product (not ready to eat milled rice), our magnets which we have several in the process remove most all of this threat, and the ones that our metal detector does catch are 99.9% smaller than the FDA tollerance for a choking hazard.

 

I am trying to formulate a change that will allow us to still produce safe product however in the event of the metal detector being shut down our HACCP plan does not hand cuf us from still operating.

 

Any ideas would be appreciated.

[larissaj]

It depends of the process after the magnets. So if it goes to the magnets and then packaged with minimal metal in between it can possibly work but you would have to check your HACCP plan and if it is possible then of course rewrite your HACCP plan. Why did the metal detector fail? Maybe solving that issue can also help so that nothing major gets changed. 

[The Food Scientist]

In this case its not that your CCP is metal detector or magnet or both, it's simply "physical hazards". Which are reduced or eliminated using magnets and/or metal detectors. Wasn't anyone monitoring these detectors hourly? Any Preventive Maintenance? If your metal detector is out of service which is used to eliminate/reduce your CCP, then you shouldn't be moving forward until you fix the issue with it. Hold your product. Have your contractor fix the issue and make recommendations, reassess your PM and monitoring programs.

[FoodSafetyPlanet]

You’d also need to verify and validate the magnets, which could turn into a project.

Additionally, since they serve the same purpose, an auditor might perceive as you are anticipating the detector to fail and question why you went with that to begin with.

I recommend first evaluating the purpose and value of each.

Edited by FoodSafetyPlanet, 12 July 2019 - 12:26 AM.

[Charles.C]

Needless to say, this type of query has been discussed here previously, eg

 

https://www.ifsqn.co...and-re-testing/

https://www.ifsqn.co...ring-operation/

 

The basic problem is that the current operational haccp plan has now broken down so if you were/are still producing the failure to monitor/document a CCP is rather "crucial".

 

Offhand, the only immediate option I can see (as a "corrective action")(other tnan dumping) would be to segregate the material produced after MD failure for subsequent scanning. This would be equivalent to having encountered a detection failure in the (presumably included in the existing haccp plan) repetitive use of test wands. It would possibly also involve some artistic ability with respect to documentation.

 

IMEX, the avoidance of this, almost inevitable sometime, event was to invest in a 2nd hand back-up unit . Not a fortune these days.

 

The other option discussed in this thread of relocating the CCP, ie revalidating the haccp plan, will depend on the process/risk assessment/hazard analysis and maybe FS standard (if any) which are unknown.

Edited by Charles.C, 12 July 2019 - 03:34 AM.
edited

[moskito]

Hi,

 

following Charles' answer it is a quesition of size to have back-up equipment available. Another question is whether the type available fits into the line especially in combination with check weigher. The next question is whether the equiment fits in the dimensions of the detector itself -> sensitivity.

We would use such equipment in that case after the "end of line" to have still a continuous process - if sufficient space is available.

We have equipment available used for semi-finished products (which will be transported to one of our other plants or to 3rd party packaging). In that case we would have to prioritize.

What we also have in place is a maintenance contract (frist level) which also can include delivery of equipment for short term exchange until our equiment is ready again.

Experience: Until now we have only once received an exchange unit (but an x-ray, not a MD). All other troubles could be solved on the equiment itself.

 

But again, this is not easy for a small company with 2 lines and 2 MD. Here I see only the option to run production on stock, blocking the products and run MD afterwards. This is possible only in the case if the finished product is not packed  e.g. with metallized film.

 

Rgds

moskito