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Egg facility, one-piece detectable pens or not? - Please advise


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#1 FoodSafetyAPP

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Posted 27 May 2020 - 09:45 AM

Morning Everyone. 

 

I have a question and I need honest opinions!

 

We are an egg packing site, low risk, no CCP's. 

 

The amount we deal with open product is limited and even so it is an egg so in it's own protection shell. (We take a pallet off a truck, travels around 50 metres onto the loader and that is that - we don't physically touch an egg and all eggs come out of the machine already packed. We use no foreign body detection equipment. 

 

DO YOU THINK WE NEED TO HAVE METAL DETECTABLE ONE PIECE PENS? or are normal pens sufficient for this situation? Maybe as long as they are controlled somehow?

 

Pens are only used by QC and supervisors. so tops up 5 people. 

 

Please advice what you think is necessary in this situation. Is something like this entirely our decision as long as we have risk assessed?

 

 

 

TIA



#2 zanorias

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Posted 27 May 2020 - 10:12 AM

Morning Zoe,

 

It's an interesting question given the product/process. BRC for example require controlled pens in open product areas though considering the risk of contaminating an egg with pen components it does seem unnecessary. I suppose one argument for MD pens would be increased chance of a customer detecting a pen/piece in their detectors if bulk detecting?

 

If you aren't specifically required by a customer or standard to use one piece detectable pens, I'd certainly conduct a risk assessment before hand to confirm the outcome and justify to auditors. However as you mentioned only a small number of people use them, and presumably more reliable staff, personally I'd be tempted to buy a box anyway and remove any doubt, since they aren't that expensive if you can make them last. The trouble I have is 20+ production staff constantly losing/forgetting them  :headhurts:



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#3 pHruit

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Posted 27 May 2020 - 12:35 PM

Morning Zoe,

 

It's an interesting question given the product/process. BRC for example require controlled pens in open product areas though considering the risk of contaminating an egg with pen components it does seem unnecessary. I suppose one argument for MD pens would be increased chance of a customer detecting a pen/piece in their detectors if bulk detecting?

 

If you aren't specifically required by a customer or standard to use one piece detectable pens, I'd certainly conduct a risk assessment before hand to confirm the outcome and justify to auditors. However as you mentioned only a small number of people use them, and presumably more reliable staff, personally I'd be tempted to buy a box anyway and remove any doubt, since they aren't that expensive if you can make them last. The trouble I have is 20+ production staff constantly losing/forgetting them  :headhurts:

 

This could well be a significant factor - theoretically related to the customer's ability to detect in their subsequent use, but in reality it may come down to "our requirement states..." even if there is an entirely valid risk assessment and a basic application of common sense suggests that the chances of you getting bits of a standard pen inside an egg are low...



#4 FoodSafetyAPP

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Posted 27 May 2020 - 12:43 PM

This could well be a significant factor - theoretically related to the customer's ability to detect in their subsequent use, but in reality it may come down to "our requirement states..." even if there is an entirely valid risk assessment and a basic application of common sense suggests that the chances of you getting bits of a standard pen inside an egg are low...

 

 

Not required by any customer -

 

I conducted a RA and implemented a policy stating only one piece metal detectable pens, as i simply would rather have something in place than to not and get penalized for it. I came to order some more pens and they are not cheap, and thought about the history i've had when auditing the place - i haven't found pens on floors, or seen them dotted around anywhere, and not many people use pens, so thought actually is it necessary? This would be a food quality issue for us and not a food safety. 



#5 MsMars

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Posted 27 May 2020 - 01:47 PM

From what you've described, I would say not necessary.  I would definitely use one-piece pens, but no need for the extra cost of being metal-detectable unless you end up with an incident down the road and have to re-assess your plan. 

 

Previously used them and was in charge of ordering them, and they were not fun to order (customer service of a particular company was sub-par), not fun to maintain, and constantly got complaints from the techs about them (they were not great quality as a writing utensil). This was a few years back, so maybe this company and the metal-detectable industry has improved the design.



#6 FurFarmandFork

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Posted 28 May 2020 - 03:16 PM

Companies switch to one piece pens the first time the customer finds a cap, then metal detactable ones the firs ttime a customer finds pieces. :)

 

In shelled eggs I see no obvious risk, still could do as a way to just standardize what's on the floor. But you probably have more higher risk issues to work on.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

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