The knifes simply never break, at least this has never happened before the knife was due replacement anyway. The issue is our IFS auditor considers this a CCP but I am struggling with what my critical limits are.
Yr auditor may be confused over haccp.
Product/Process is unknown.
afaik IFS is based on Codex haccp.
A possible CCP is metal inclusion.
Codex haccp (2020) allows a critical limit to be measurable or observable. However I note that ifs (following iso22000 ?) has "Control measures, other than CCPs, shall be monitored, recorded and controlled by measurable or observable criteria". If a measurable criterion is necessary, can set the (visual) critical limit > 0.0 mm 
Details of the handling of above CCP (if it exists) are usefully detailed in Pgs 385-393 of enclosed document.
SeafoodHazardsGuide-Fish-and-Fishery-Products-Hazards-and-Controls-Guidance-Fourth-Edition-August2019.pdf 4.12MB
21 downloads
(esp pgs 386, 391 et seq)
PS - Also note that various modern CCP decision trees typically start with the question - Can a PRP handle this hazard ? Assuming Yes, then define routine control/inspection of the condition of knives as a PRP.
Edited by Charles.C, 10 September 2021 - 05:47 AM.
edited