On my last BRC audit, the auditor mentioned that I must validate our CCP (MD) from a difference perspective. Basically, I need to validate that the product does not contains any metal particle, instead of validate that my MD is working properly or the size of CL are the correct ones. He mentioned that FDA has a guideline in Chapter 21 under cereal and snacks, where it recommends to do an Ash content testing to the finished product to validate that it does not contains metal particles.
This is the first time I'm hearing something like this, I couldn't find any helpful information in FDA portal and I have also asked different people in the industry and no one has made this type of testing for validation of Metal Detectors. Could someone please give me an advice? Is this a new trend in the industry? If so, could you please share a link and advice on the specs for this testing?