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Setting measurable and critical limit for a sieve used for non-metal physical hazards


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#1 ain-sha

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Posted 22 July 2020 - 07:41 AM

Hi, I would like to get some opinion/ suggestion on changing current CCP that is observable to a measurable and possible critical limit.

     

        Process             Control measure             Critical limit                      Monitoring

Vibrator sieving           sieve integrity                  sive size;                     Visual check

                                                                   no broken wire mesh

 

 

It is a CCP due to its function to trap non-metal physical hazards.

However, I stuck to provide a measurable control limit.

 

AinSha,

Shah Alam, Malaysia

 

               



#2 HCFtech

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Posted 22 July 2020 - 08:05 AM

Surely you have answered this yourself, the control limit is no broken wire mesh? Focus on how you control the corrective actions if you don't have replacement seive's immediately available or time restrictions on replacing broken wires.



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#3 mahantesh.micro

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Posted 22 July 2020 - 11:59 AM

Hi Ain-sha

I faced same issue, we use 20 (0.84 mm) mesh for sieving our product, we have made it CCP. What we measure is the sieve opening with screw gauge at random sites and record the actual size of the mesh. We have set limit 0.841 mm to 0.905 mm. 



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#4 Charles.C

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Posted 23 July 2020 - 07:13 AM

Hi, I would like to get some opinion/ suggestion on changing current CCP that is observable to a measurable and possible critical limit.

     

        Process             Control measure             Critical limit                      Monitoring

Vibrator sieving           sieve integrity                  sive size;                     Visual check

                                                                   no broken wire mesh

 

 

It is a CCP due to its function to trap non-metal physical hazards.

However, I stuck to provide a measurable control limit.

 

AinSha,

Shah Alam, Malaysia

Why do you seek to change ? Because of a change in text of Standard ?


Kind Regards,

 

Charles.C


#5 mahantesh.micro

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Posted 23 July 2020 - 04:01 PM

Why do you seek to change ? Because of a change in text of Standard ?

Charles

As per new ISO22000-2018 std, definition of Critical limit has been changed. So we need to set measurable critical limits, if we make any step as CCP then it must have measurable critical limit and we cannot set observable action criteria for CCPs (example: present/absent, go/no go, etc), if it is OPRP then we can have measurable or observable action criteria. 



#6 Charles.C

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Posted 23 July 2020 - 04:52 PM

Charles

As per new ISO22000-2018 std, definition of Critical limit has been changed. So we need to set measurable critical limits, if we make any step as CCP then it must have measurable critical limit and we cannot set observable action criteria for CCPs (example: present/absent, go/no go, etc), if it is OPRP then we can have measurable or observable action criteria. 

Hi MM,

 

Yes, that was the reason I asked.

 

In fact the new version has already been criticisedi n the Literature for this change.

 

Just another reason in many to avoid using this conceptually overloaded Standard IMHO.


Kind Regards,

 

Charles.C


#7 QA_Spices

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Posted 23 July 2020 - 09:11 PM

Ain Sha,


Edited by QA_Spices, 23 July 2020 - 09:16 PM.


#8 mahantesh.micro

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Posted 24 July 2020 - 04:12 AM

Hi MM,

 

Yes, that was the reason I asked.

 

In fact the new version has already been criticisedi n the Literature for this change.

 

Just another reason in many to avoid using this conceptually overloaded Standard IMHO.

 

Right Charles,

But Shah Alam has made sieving step as CCP, then he must set measurable critical limits, now if he changes this step in to OPRP then he must justify it to the auditor.

 

What is your opinion on this??



#9 Charles.C

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Posted 24 July 2020 - 10:47 PM

Right Charles,

But Shah Alam has made sieving step as CCP, then he must set measurable critical limits, now if he changes this step in to OPRP then he must justify it to the auditor.

 

What is your opinion on this??

Hi MM,

 

A related discussion occurred here -

 

https://www.ifsqn.co...om-ccp-to-oprp/

 

The semantic mess due new revision is discussed in "depth" in file below (parts of which I do not fully agree) -

 

Attached File  iso22000(2018) - the CCP-OPRP-PRP mess.pdf   228.64KB   39 downloads

 

IMO the 3 most pragmatic options are -

 

(1) Designate as PRP based on iso2202-1 section 10.4. (this may logically have additional, potential, repercussions).

(2) Use a decision tree/decision chain to make sieving step associated with an OPRP  based on inability for continuous monitoring (this IMO could have equally been done prior to the 2018 version).

(3) Avoid using iso22000.

 

Do you see any objections to (1) ?  I appreciate that 2 conceptual objections are via these kind of (quoted) interpretations/comments - 

 

"PRP’s are usually general to the process [hygiene?] and not focused on any particular step in the process"

"Failure of a PRP does not necessarily lead to an immediate and imminent food safety risk" .)

 

I suggest that accepting iso22002-1 as (Pre-hazard analysis)  PRP-applicable (as now defined in 2018 text) effectively "relaxes" above restrictions. (It is a reality that even the  pre-2000 haccp presentations (eg NACMCF) attributed a variable scope to PRPs [eg as facility hygiene related + QA adjuncts]).


Kind Regards,

 

Charles.C


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#10 mahantesh.micro

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Posted 25 July 2020 - 04:36 AM

Hi MM,

 

A related discussion occurred here -

 

https://www.ifsqn.co...om-ccp-to-oprp/

 

The semantic mess due new revision is discussed in "depth" in file below (parts of which I do not fully agree) -

 

attachicon.gif iso22000(2018) - the CCP-OPRP-PRP mess.pdf

 

IMO the 3 most pragmatic options are -

 

(1) Designate as PRP based on iso2202-1 section 10.4. (this may logically have additional, potential, repercussions).

(2) Use a decision tree/decision chain to make sieving step associated with an OPRP  based on inability for continuous monitoring (this IMO could have equally been done prior to the 2018 version).

(3) Avoid using iso22000.

 

Do you see any objections to (1) ?  I appreciate that 2 conceptual objections are via these kind of (quoted) interpretations/comments - 

 

"PRP’s are usually general to the process [hygiene?] and not focused on any particular step in the process"

"Failure of a PRP does not necessarily lead to an immediate and imminent food safety risk" .)

 

I suggest that accepting iso22002-1 as (Pre-hazard analysis)  PRP-applicable (as now defined in 2018 text) effectively "relaxes" above restrictions. (It is a reality that even the  pre-2000 haccp presentations (eg NACMCF) attributed a variable scope to PRPs [eg as facility hygiene related + QA adjuncts]).

But our company has been certified ISO 22000-2005 and now we are transitioning to 2018 version, we have to follow the standard.

 

in your previous attachment itself it is explained that sieving step can be monitored by measuring the mesh size. Continuous monitoring is possible here and frequency can be fixed based on the historical data.



#11 Charles.C

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Posted 25 July 2020 - 11:30 AM

But our company has been certified ISO 22000-2005 and now we are transitioning to 2018 version, we have to follow the standard.

 

in your previous attachment itself it is explained that sieving step can be monitored by measuring the mesh size. Continuous monitoring is possible here and frequency can be fixed based on the historical data.

Hi MM,

 

Note that i said I did not agree with all the content of my attachment.

IMO the opening paragraph of sec.3 is simply a semantic fudge.

Similarly the last paragraph of sec.1.

I also found it curious that the attachment seemingly ignored iso22002-1 with respect to sec.10.

 

Whatever, the Standard's experts  introduced these artificial subtleties and  deserve to face the consequences.

 

All these semantic zigzags plus aspects like the attempts to justify the continuing use of OPRP are IMO why this Standard is an absolute mess from a haccp POV.

 

There are 2 more prolonged/contentious threads on this topic here -

 

https://www.ifsqn.co...g-can-be-a-ccp/

(2008)

https://www.ifsqn.co...p-verification/

(2019)

 

Regardless of the endless debate over  hazardous, particle sizes,  I am impressed that you can continuously monitor the mesh size. How do you do it ?

 

Once again, IMO, the direct cause for all these headaches lies with the Standard, not the users. Perhaps the real objective was to increase the use of OPRPs.

 

PS just as one sieving PRP illustration for a non-iso plan -

 

Attached File  haccp plan-black pepper.png   740.21KB   0 downloads

 

and one sieving PRP/CCP -

 

Attached File  kraft - extraneous material.png   256.4KB   0 downloads

 

and even a metal detector PRP/CCP -

 

There is an ongoing debate as to how a company’s metal detector should be incorporated into the organization’s food quality and safety programs. Some companies have determined that metal detection should be a CCP in their Hazard Analysis and Critical Control Points (HACCP) plan, whereas others deem it part of quality management (prerequisite program).

 

If the manufactured products are chopped or ground, and the company’s Hazard Analysis determines that there is a significant potential for metal contamination, the company will probably adopt the former. However, if a processor is producing purées or juices, it might install an in-line metal detection unit not only to look for metal but also to protect equipment that is located downstream of the unit. Of course, there are processors that base this decision not on risk but on customer demands. If a processor’s primary customer demands that metal detection be a CCP, they will usually comply.[3]

https://www.foodsafe...and-evaluation/

 

 

 

PPS - Most auditors are surely well aware of all these interpretations which must give them equal headaches. Unless individual experience dictates otherwise,  I suspect that in practice any of the 3 options may be acceptable provided that the associated Va/Ve data is "plausible" .


Kind Regards,

 

Charles.C





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