6 replies to this topic

[japarzu]

Hi,

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?

[Hank Major]

Interesting. So your auditor is suggesting that you send out a big sample to be reduced to ash, then have the ash tested for metal content by mass spectroscopy?

[japarzu]

That's correct, he suggested to validate that our product do not contains metal residues instead of validate that our test balls are the correct ones for our process. He said that BRC is looking it from the finish product perspective and not from the equipment perspective. Any thoughts? 

[Hank Major]

Well, don't see how it Validates the metal detector. If anything, it would show that the metal detector can't detect fine metal particles.

[Charles.C]

Hi,

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?

 

Do you have a link to chapter 21 ?

 

Offhand, it sounds like the auditor has given you the Codex method for validating a sieve using a MD.

[Leila Burin]

Hello,

the BRC doesn´t at all mention to validate the MD, to which requisite has the auditor reference to?

 

Anyway, on my opinion the best way to vadite the MD is to carry a 25x times test on a swarf metal scarf from the maintenance shop, within the product,

best regards,

 

Leila

[Charles.C]

The OP omitted to mention what product/process was involved.

 

There are a load of semantic subtleties prevailing in this area.

 

afaik many (all?) food products in USA are under the jurisdiction of either FDA/USDA in which case any appropriate Regulatory requirements will presumably supercede BRC's own opinion.

 

the BRC auditor's comment might conceivably relate to the validation of a  critical limit(CL) since this "definition"  of CL occurs in FDA's 2019 Fishery manual -

 

 FDA, MD - critical limit.PNG   21.59KB   1 downloads

 

Nonetheless, above document makes no reference to "ashing" the product !.