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Metal Detection of Ingredients Shipped to Co-Packer

Quality Assurance HACCP Food Safety CDPH FDA BRC CCP Ingredient Supplier Hazard Analysis

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#1 Kristen123

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Posted 30 September 2020 - 11:05 PM

Hi All, 

 

I have a unique metal detection question. 

 

I have a facility that manufactures ingredients that will then be shipped to a co-packer.

 

We do not manufacture ingredients straight to consumer, only to supply the single co-packer. 

 

I will preface this with we are still in the beginning stages and not producing yet. 

 

If we are manufacturing these ingredients not for consumer use, but to be shipped to a co-packer, is a metal detector required? 

 

Is a metal detector required if we have an agreement with the co-packer that they will metal detect and control the potential hazard? 

 

We will be going for a BRC cert once closer to producing, but need to know if this is a requirement or an agreement would suffice if we only supply to the one co-pack facility. 

 

Thank you in advance!



#2 Charles.C

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Posted 01 October 2020 - 05:34 AM

Hi kristen.

 

I doubt that it's unique.

 

I would anticipate that you may need operational validation of yr agreement/results.


Kind Regards,

 

Charles.C


#3 Kristen123

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Posted 01 October 2020 - 06:09 PM

Hi Charles, 

 

Thank you for the response. 

 

Are you aware of any regulations or literature I can use to confirm I would only need the operational validation on a 1 year agreement in place of an in-facility metal detector?

 

Thank you, 

 

Kristen



#4 moskito

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Posted 02 October 2020 - 03:08 PM

Hi Kristen,

 

is there a requirement ? I think NO.

 

What we are doing as a bakery:

- any raw material delivered to us has to pass a foreign body reduction step (MD, x-ray, filtration or sieving)

- any semi-finished product leaving our factor e.g. for packaging has passed a MD or x-ray (even if the co-packer is a plant within our organisation/intra-company shipment)

- any semi-finished product we receive from a contract manufacturer has passed a MD or x-ray.
- any finished product leaving our factory has passed a MD or x-ray.

 

Finally, we as a customer have the requirement for such procedures being in place.

 

Rgds

moskito



#5 A123R

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Posted 08 October 2020 - 09:14 AM

Hello,

 

I have the same dilema at the factory I work.

 

We manufacture ingredients for other manufacturers and metal detecting bulk product won't be easy due to mainly space issues. I have tried finding some guidance for this scenario but with no luck. All decision trees and guidance refer to the risk of your product containing metal and do not consider if there will be a subsequent step reducing the risk (in this case, at your customer facilities). This is open to interpretation as if you come to the conclusion of "metal detector required" you might be able to say it is in place (customer facilities). 

 

I would say that as long as it is well justified - i.e. assessment of the risk of metal contamination at your facilities, history of metal contamination and specially agreement with the customer in place (product to be used exclusively as an ingredient in finished products which will go through a metal detector or equivalent system), we should be fine. 

 

It would be great however to get another opinion from someone who has been in the same situation







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