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Canadian Metal Detectable Limits

CCP Metal detection Critical Limits Canada

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gsam711

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Posted 30 December 2021 - 05:07 PM

Company produces flour tortillas and pocket bread.  

 

Our current ccp limits are 3.5mm across the board.  However, Canada requires 2.0mm...our machines are not able to be calibrated that low and function properly (per the company that handles our validation and Maintenace on the machines).

 

Is there a way to challenge that regulation for Canada?  The us is 7mm.

 

Thanks, 



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Charles.C

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Posted 03 January 2022 - 12:06 PM

Company produces flour tortillas and pocket bread.  

 

Our current ccp limits are 3.5mm across the board.  However, Canada requires 2.0mm...our machines are not able to be calibrated that low and function properly (per the company that handles our validation and Maintenace on the machines).

 

Is there a way to challenge that regulation for Canada?  The us is 7mm.

 

Thanks, 

 

Hi gsam,

 

2 comments -

 

I doubt the veracity of your Maintenance Company although it may depend on what they mean by "Calibration/properly".  It appears to mean that yr MD is unable to detect a standard test 2mm sphere of ferrous metal.  Do you have an antique MD which has unusually low sensitivity.

 

You may (freely) consider asking the USFDA what level of metal contamination is considered acceptable in commercialised food products (ie not adulterated). I predict the answer will be "Zero" as discussed in various previous threads here. The 7mm "tolerance" needs to be interpreted in the context of the FDA's lengthy Official Regulations.

 

On the other hand, you might usefully consider asking CFIA how they justify their 2mm requirement (I am not aware of a published validation).


Kind Regards,

 

Charles.C


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Scampi

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Posted 03 January 2022 - 02:36 PM

you will get no headway when trying to argue against the limits for metal detection

 

A) they are set by Health Canada, and enforced by CFIA as they are choking hazard size for children, and since you're product would be fed to children, there will be zero wiggle room

 

Health Canada has developed a guidance document for determining the general cleanliness of foods. The document, Guidelines for the General Cleanliness of Food - An Overview includes information on foreign matter associated with objectionable conditions or practices in manufacturing, processing, storing, transporting and handling of food. Health Canada considers 2.0 mm or greater as the threshold size for consideration as a health risk.[1]

 

 

B) you could get an adjustment made to your aperture so it can detect that size

 

It is your responsibility, when exporting to ANY country, to meet they importing countries requirements


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Charles.C

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Posted 03 January 2022 - 08:21 PM

you will get no headway when trying to argue against the limits for metal detection

 

A) they are set by Health Canada, and enforced by CFIA as they are choking hazard size for children, and since you're product would be fed to children, there will be zero wiggle room

 

Health Canada has developed a guidance document for determining the general cleanliness of foods. The document, Guidelines for the General Cleanliness of Food - An Overview includes information on foreign matter associated with objectionable conditions or practices in manufacturing, processing, storing, transporting and handling of food. Health Canada considers 2.0 mm or greater as the threshold size for consideration as a health risk.[1]

 

 

B) you could get an adjustment made to your aperture so it can detect that size

 

It is your responsibility, when exporting to ANY country, to meet they importing countries requirements

 

Hi Scampi,

The link(s) seem to lead (> extraneous materials overview) to an email address.

I recall there used to be a detailed page on this topic on the CFIA website. Removed from public view ?.

Validation unknown.

(USDA also used to quote 2mm but I believe have now "rationalized" to USFDA's POV which has its own multiple nuances.

In reality, there are occasional rejections in USA for metallic "dust" via their unique (?) adulteration logic).


Kind Regards,

 

Charles.C


Scampi

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Posted 14 January 2022 - 07:14 PM

as i mentioned, it's governed by Health Canada, and CFIA is charged with enforcement

 

https://www.canada.c...al-methods.html

 

You can request the method following the link above

Physical Hazards

 


Illness and injury can result from hard foreign objects in food. These physical hazards can be introduced anywhere along the food chain from the field source up to and including the consumer. They can be inherent in the product, of field origin or derived raw materials or packaging. They can originate from many different sources (for example, on the processing line from plant equipment or employees).

Many types of extraneous material may be present in foods. Examples of physical hazards include:

  • bone or shell fragments, hair or feathers from animal products
  • stones, rocks and dirt (commonly found in fruits, vegetables and other foods that are grown close to the soil)
  • metal (commonly associated with processing activities such as cutting, slicing or grinding operations, as well packaging materials or containers such as metal shards, staples and nails)
  • jewelry and personal items (resulting from poor food handling practices)
  • glass or other contaminants from packaging materials or containers, or from the processing environment, for example, uncovered light fixtures
  • wood splinters from broken pallets or packaging material
  • flaking paint from overhead structures or equipment
  • insect pieces
"Other Information Unavoidable and avoidable extraneous material

Unavoidable and avoidable extraneous materials are two categories used to differentiate extraneous material in food.

Unavoidable extraneous material may occur in food as a by-product of the processing system or as something inherent to the product itself. Items such as stems in blueberries, microscopic airborne debris, dirt on potatoes, or minute insect fragments in figs are common examples of unavoidable extraneous matter.

Avoidable extraneous material consists of foreign matter which should not be present if proper GMPs are followed. Avoidable extraneous material may come in many different forms such as small glass fragments, pieces of plastic, chunks of rubber, pieces of jewelery, feather barbules, animal debris or any other unrelated foreign material.

Health Canada has developed a guidance document for determining the general cleanliness of foods. The document, Guidelines for the General Cleanliness of Food - An Overview includes information on foreign matter associated with objectionable conditions or practices in manufacturing, processing, storing, transporting and handling of food. Health Canada considers 2.0 mm or greater as the threshold size for consideration as a health risk.[1]"


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sjegorov

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Posted 14 January 2022 - 09:07 PM

Company produces flour tortillas and pocket bread.  

 

Our current ccp limits are 3.5mm across the board.  However, Canada requires 2.0mm...our machines are not able to be calibrated that low and function properly (per the company that handles our validation and Maintenace on the machines).

 

Is there a way to challenge that regulation for Canada?  The us is 7mm.

 

Thanks, 

Hi, Do you only metal detect product when it's in boxes? 3.5 mm more relevant to large bulk boxes. Have you got inline/belt metal detectors?



Charles.C

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Posted 15 January 2022 - 10:58 AM

 

as i mentioned, it's governed by Health Canada, and CFIA is charged with enforcement

 

https://www.canada.c...al-methods.html

 

You can request the method following the link above

Physical Hazards

 


Illness and injury can result from hard foreign objects in food. These physical hazards can be introduced anywhere along the food chain from the field source up to and including the consumer. They can be inherent in the product, of field origin or derived raw materials or packaging. They can originate from many different sources (for example, on the processing line from plant equipment or employees).

Many types of extraneous material may be present in foods. Examples of physical hazards include:

  • bone or shell fragments, hair or feathers from animal products
  • stones, rocks and dirt (commonly found in fruits, vegetables and other foods that are grown close to the soil)
  • metal (commonly associated with processing activities such as cutting, slicing or grinding operations, as well packaging materials or containers such as metal shards, staples and nails)
  • jewelry and personal items (resulting from poor food handling practices)
  • glass or other contaminants from packaging materials or containers, or from the processing environment, for example, uncovered light fixtures
  • wood splinters from broken pallets or packaging material
  • flaking paint from overhead structures or equipment
  • insect pieces
"Other Information Unavoidable and avoidable extraneous material

Unavoidable and avoidable extraneous materials are two categories used to differentiate extraneous material in food.

Unavoidable extraneous material may occur in food as a by-product of the processing system or as something inherent to the product itself. Items such as stems in blueberries, microscopic airborne debris, dirt on potatoes, or minute insect fragments in figs are common examples of unavoidable extraneous matter.

Avoidable extraneous material consists of foreign matter which should not be present if proper GMPs are followed. Avoidable extraneous material may come in many different forms such as small glass fragments, pieces of plastic, chunks of rubber, pieces of jewelery, feather barbules, animal debris or any other unrelated foreign material.

Health Canada has developed a guidance document for determining the general cleanliness of foods. The document, Guidelines for the General Cleanliness of Food - An Overview includes information on foreign matter associated with objectionable conditions or practices in manufacturing, processing, storing, transporting and handling of food. Health Canada considers 2.0 mm or greater as the threshold size for consideration as a health risk.[1]"

 

Hi Scampi,

 

As per Post 4 the links seem to require initiating an email conversation. Not very helpful.
 

I wonder why the "2mm" material has apparently been removed from website. Zero validation ?

 

The CFIA hazard database document now has afaik the only directly accessible details.


Kind Regards,

 

Charles.C






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