HACCP Monitoring Procedures - Corrective Action and Verification

Hello guys, I have a question. Is this wrong? (I believe it is wrong) Note: The Metal Detector is the Critical Control Point.
Monitoring: Step where we identify how we will make sure that the process meets the critical limit. Example: The Quality Control Technician performs metal detector checks every hour to ensure proper operations of the metal detector. Corrective Action: Refer to the actions taken when a critical limit is not met. Example: Suppose the metal detector is not working or the check is not documented. In these cases, all products are placed on-hold and rechecked through a functioning metal detector. Verification: Step where we confirm the employees follow the monitoring procedures. Example: Supervisor observes if the Quality Control employees are following the monitoring procedures and record keeping properly.

Hello, 

I have worked with 3 companies and I never put a Metal Detector has a Critical Control Point. 

When you have the metal detector has a CCP you have very little room to work with.  

If you can I would put it as an Prerequisite Program. 

Hello guys, I have a question. Is this wrong? (I believe it is wrong)

 

Note: The Metal Detector is the Critical Control Point

 

Monitoring: Step where we identify how we will make sure that the process meets the critical limit.

Example: The Quality Control Technician performs metal detector checks every hour to ensure proper operations of the metal detector.

 

Corrective Action: Refer to the actions taken when a critical limit is not met.

Example: Suppose the metal detector is not working or the check is not documented. In these cases, all products are placed on-hold and rechecked through a functioning metal detector.

 

Verification: Step where we confirm the employees follow the monitoring procedures.

Example: Supervisor observes if the Quality Control employees are following the monitoring procedures and record keeping properly.

Hello, 

 

I have worked with 3 companies and I never put a Metal Detector has a Critical Control Point. 

 

When you have the metal detector has a CCP you have very little room to work with.  

 

If you can I would put it as an Prerequisite Program. 

@ Mic.Sci. -  Not sure if this is a "trick" question ?

So what did you not agree with ?

It might have assisted if you had provided a  little more context, eg  Product/Process/Source of Quote[?]/Standard. These and others can all influence a HACCP-related query.

@ HokiPokey - I deduce you assumed the OP was querying as to whether "metal detection"  is a CCP. This may not have been the intended question. For example, assuming it is a CCP, Line 3 seems semantically dubious ?,  Line 8 looks incorrect  in comparison to typical, eg Codex, definitions of Verification ?

If one wishes to delve into the various opinions on the "status" of the metal detection step can plough through one of the longest running active and the most viewed  thread on this Forum, ie - 

https://www.ifsqn.co...etal detection

One can find Literature support for setting a metal detection step as either a PRP or a CCP. I suggest these interpretations  are fairly typical  for "traditional" haccp -

Kraft Extraneous Materials.pdf   174.41KB   147 downloads

PRP or CCP.pdf   391.69KB   194 downloads

(esp. see appended discussion)

Sorry if you guys can not understand. English is my second language.

I am developing an online training (HACCP) for the Quality Control Technicians . Somebody is helping me develop the training. We are using the metals detector as an example of a CCP. The person I am working with says: 

1.  That MONITORING  procedure is done by the Quality Control Technician when she/he pass the wands/strips used to verify that the metal detector is working properly.

I say the MONITORING procedure is the metal detector it self detecting any piece of metal in the product. 

2. My colleague says that the VERIFICATION procedure is the Supervisor observing if the Quality Control employees are following the monitoring procedures and record keeping properly. 

I say: VERIFICATION is when the Quality Control Technician pass the wands/strips used to verify that the metal detector is working properly. And of course it also can be what my colleague is saying expect that the Quality Control Technician does not follow the monitoring procedures - the metal detector does the monitoring. 

I hope you guys can understand - Thanks for your responses!!! 

Sorry if you guys can not understand. English is my second language.

I am developing an online training (HACCP) for the Quality Control Technicians . Somebody is helping me develop the training. We are using the metals detector as an example of a CCP. The person I am working with says: 

1.  That MONITORING  procedure is done by the Quality Control Technician when she/he pass the wands/strips used to verify that the metal detector is working properly.

I say the MONITORING procedure is the metal detector it self detecting any piece of metal in the product. 

 

2. My colleague says that the VERIFICATION procedure is the Supervisor observing if the Quality Control employees are following the monitoring procedures and record keeping properly. 

I say: VERIFICATION is when the Quality Control Technician pass the wands/strips used to verify that the metal detector is working properly. And of course it also can be what my colleague is saying expect that the Quality Control Technician does not follow the monitoring procedures - the metal detector does the monitoring. 

 

I hope you guys can understand - Thanks for your responses!!! 

Hi Mic.Sci,

Your English is fine.

It looks like you have some confusion over terminologies like Validation, Verification and Monitoring which is not unusual  even for HACCP "experts"

The 2 illustrative attachments below may help although the validation stage is not included. This would usually be carried out as a specific program so as to enable designation of an appropriate critical limit, prior to the start of monitoring.

The Column "Deviation Procedures"  includes "corrective actions"

Process Flowchart.pdf   154.98KB   133 downloads

Metal detector CCP.pdf   412.16KB   190 downloads

PS - Note that the procedure in monitoring of placing a wand on top of the product may vary depending on the dimensions of product and metal detector (MD) aperture. Ideally the wand is embedded within the product such that it passes through the axial centre of a (horizontal) MD aperture but this may not be practically possible for some situations.

This is an interesting situation. The document you sent me say: "Monitoring Procedures - Once every Y time period, the Monitor passes each of the following metal wands through the metal detector - x mm ferrous, x mm non-ferrous, x mm stainless." My colleague says the same as the document you send me.

But a got a document from the FDA that says: Verification Procedures "Challenge the metal detector using validated sensitivity standards daily, at the start of production, every 4 hours during operation...". I am assuming metal wands is the same as sensitivity standards. 

The document from the FDA says: "Monitoring Procedures: Product monitoring is performed by the metal detector or separation device itself".

This is why I say that the Monitoring Procedure is the metal detector itself. The critical limits is no metal detectable and the verification is passing the sensitivity standards (metal wands) though the metal detector. 

Thanks for your help!!!

This is the link for the FDA document: Fish and Fishery Products Hazards and Controls Guidance (fda.gov)

Thanks!!!

I think see your confusion.   

the critical limit is "a operating metal dectector".  

How do you prove its operating without triggering the reject device / passing test pieces?

if passing test pieces is monitoring that you have a operational metal detector - isn't  that is also verification?

if that is your confusion,  you are correct (it doesn't make sense).    in the case of the metal detector monitoring and verification are nearly the same thing (when you follow the fda document)  I believe a similar example is given in the PCQI manual.

This is the link for the FDA document: Fish and Fishery Products Hazards and Controls Guidance (fda.gov)

 

Thanks!!!

Hi Mic.Sci.

You should re-read Post3 again.

Is yr business with fish in USA or  ?

My examples were ex CFIA, ie Canadian, which afaik follows various USFDA procedures but for sure not all.

It is a well-known fact that this area of terminologies can be a minefield. If you wish to make meaningful comparisons/evaluations you really need to provide context.

Just as another example, I attach an implemented  haccp plan (inc. metal detector) for US almond processing. I anticipate this is under FDA jurisdiction. You may compare the critical limits and verification.columns and observe the differences to both  yr linked document and also my previous attachment.

IMO it is probable that "interpretations" of the FDA's, IMO, quantitatively ambiguous text are being found necessary for practical purposes.

haccp program California almonds.pdf   566.2KB   135 downloads