Metal Detection Requirement
Help please!
'Metal detection equipment shall be in place unless risk assessment demonstrates that this does not improve the protection of final products from metal contamination. Where metal detectors are not used justification shall be documented. The absence of metal detection would only normally be based on the use of an alternative, more effective method of protection (e.g. use of X-ray, fine sieves or filtration of products).'
W have two lines in our plant with metal detection, the third does not have a metal detector because - the packing meterial contains metal, which is something that we actually can't avoid right now.
So how do I go about risk assessing my way out of this one?
This is what I have so far -
The mix goes through a very fine sieve, and there are not many process steps after sieving. We have added the sieve as close to filling as we possibly can.
We do add some more raw materials after the sieving, some in solid form and some in liquid.
All of our suppliers have some sort of foreign object detection as declared in their RMQ. So we would hope they are metal free!
There are basically 3 possibilities of contamination
-raw materials (they guarantee to be free from foreign matter)
-Our own process machinery (always a chance a pump can grind or whatever)
-From the sorroundings (not very likely,but sometimes it does happen in industry, loose screws or whatever).
We have never had the metal detectors on the other lines pick up metal, and they share a lot of the same raw materials and sometimes some of the same prcoess equipment (it can be moved fom line to line).
We have also never had a customer complaint about metal.
I am actually not that concerned about metal contamination, it's not a process that is likely to pose a risk.
So many experts in the field here - would an auditor be satisfied with my arguements or is there more I should consider?
In my experiece, if we did start to have metal contamination, it is most likely to be small shard from a pump grinding on itself, which would not be picked up by the metal detector until suddenly bigger pieces started to come off. Hopefully this will never happen, thats why we have preventative maintenance right!
Help please!
'Metal detection equipment shall be in place unless risk assessment demonstrates that this does not improve the protection of final products from metal contamination. Where metal detectors are not used justification shall be documented. The absence of metal detection would only normally be based on the use of an alternative, more effective method of protection (e.g. use of X-ray, fine sieves or filtration of products).'
W have two lines in our plant with metal detection, the third does not have a metal detector because - the packing meterial contains metal, which is something that we actually can't avoid right now.
So how do I go about risk assessing my way out of this one?
This is what I have so far -
The mix goes through a very fine sieve, and there are not many process steps after sieving. We have added the sieve as close to filling as we possibly can.
We do add some more raw materials after the sieving, some in solid form and some in liquid.
All of our suppliers have some sort of foreign object detection as declared in their RMQ. So we would hope they are metal free!
There are basically 3 possibilities of contamination
-raw materials (they guarantee to be free from foreign matter)
-Our own process machinery (always a chance a pump can grind or whatever)
-From the sorroundings (not very likely,but sometimes it does happen in industry, loose screws or whatever).
We have never had the metal detectors on the other lines pick up metal, and they share a lot of the same raw materials and sometimes some of the same prcoess equipment (it can be moved fom line to line).
We have also never had a customer complaint about metal.
I am actually not that concerned about metal contamination, it's not a process that is likely to pose a risk.
So many experts in the field here - would an auditor be satisfied with my arguements or is there more I should consider?
In my experiece, if we did start to have metal contamination, it is most likely to be small shard from a pump grinding on itself, which would not be picked up by the metal detector until suddenly bigger pieces started to come off. Hopefully this will never happen, thats why we have preventative maintenance right!
Hi Annette,
Maybe X-Ray detector?
https://www.loma.com...lized-packaging
Specialised MDs also exist for Al packaging.
BRC discuss some tolerances where no MD may be acceptable in their IG and also offer a decision tree.
Audit is how ever very soon, can't implement before.
Do you think my justification will fly?
Any points I can add to my justification?
I have also used the decision tree in BRC, got to the last step, then it can be a little subjective there and of course it depends a lot on the type of food, how easy it will be for the consumer to notice it before ingestion etc.
Our product is ice cream, so I actually doubt the consumer will notice it prior to ingestion.
Depending on how you look at that last step it could go either way.
Thank you Charles. I hadn't been aware that specialized MDs exist for aluminum. Good to know!
Audit is how ever very soon, can't implement before.
Do you think my justification will fly?
Any points I can add to my justification?
I have also used the decision tree in BRC, got to the last step, then it can be a little subjective there and of course it depends a lot on the type of food, how easy it will be for the consumer to notice it before ingestion etc.
Our product is ice cream, so I actually doubt the consumer will notice it prior to ingestion.
Depending on how you look at that last step it could go either way.
Hi Annette,
If your analysis determines that non--requirement of a MD will require a YES for last step of Tree i unfortunately tend to agree with yr above penultimate opinion.
The result might depend on your available evidence of any (self-unscreened) raw material supplier's metal screening capabilities (Audits?).
IMEX (a) MD units may on rare occasions reveal contaminations which would otherwise have gone undetected, (b) metal detection is invariably requested by fast food customers.
Would be interesting to get input/methodology from BRC users who have successfully justified absence of a MD.
PS - I notice that BRC do not discuss metal contamination quantitatively in the context of food safety, ie they implicitly utilize the US concept of adulteration.
Yes would love to hear from others that got through BRC with this scenario.
Like I have said, we do have a sieve- but there are other things added after the sieve.
My arguments are
Raw materials- approved suppliers with foreign object detection
Equipment- preventative maintenance
Sorroundings- good housekeeping &
Product is open for a very short time
Charles could you maybe link to an MD that is capable of testing products with aluminum as a part of the packaging?
It's not my area of expertise in any case.
Thanks!
Thanks Charles, appreciate the input. We have a supplier system in place based on RMQ where foreign object detection is part of the RMQ. All suppliers are approved and we have not ever experienced an issue with them. Audit is only something we do if the supplier cannot be approved out from our RMQ and supplier database.
Yes would love to hear from others that got through BRC with this scenario.
Like I have said, we do have a sieve- but there are other things added after the sieve.
My arguments are
Raw materials- approved suppliers with foreign object detection
Equipment- preventative maintenance
Sorroundings- good housekeeping &
Product is open for a very short time
Charles could you maybe link to an MD that is capable of testing products with aluminum as a part of the packaging?
It's not my area of expertise in any case.
Thanks!
Hi Annette,
I daresay most of the well-known suppliers probably offer Al-compatible units, just for example -
https://www.anritsu....n/aluminum-pack
Also can have a look at these threads -
https://www.ifsqn.co...rs/#entry156831
You may be able to justify not having a metal detector by
1) Historical data - no fragments detected ever over a period of n weeks/months, no customer complaints
2) Periodic checks (hourly/daily/per lot/etc) of equipment
Just a thought
If you determine your need a method for controling the risk. Would a inline filter work in your operation / process? Similar to attached. It might lead to more questions regarding validation and proper mesh size. Just I thought.
Attached Files
It probably will ultimately depend on the extent to which BRC are prepared tp "put their money where ........" :smile:
I see the risk as low to miniscule, bit we have metal detectors on the other lines so....
Anyway we are looking at options after Charles mentioned we can have a metal detector suitable for packaging with aluminum.
Thanks Charles!
Anyone have any experience with the metal detectors that can handle aluminum? Feedback from the supplier of metal detectors is that they are incredibly bulky and cannot handle stainless steel- they are incredibly sensitive to it. Anyone?
We have ferrous-in-foil MD (production of frozen pies in alu foils). It's not bulky but a real, real pain - very sensitive. MT has got one that they say can inspect product in metalised film, but I haven't worked with that machine: https://www.mt.com/g...l-detector.html
We have ferrous-in-foil MD (production of frozen pies in alu foils). It's not bulky but a real, real pain - very sensitive. MT has got one that they say can inspect product in metalised film, but I haven't worked with that machine: https://www.mt.com/g...l-detector.html
Hi sjegorov,
Thks input.
Why is being highly sensitive to ferrous contamination a pain ? Too many rejects ?
Anyone have any experience with the metal detectors that can handle aluminum? Feedback from the supplier of metal detectors is that they are incredibly bulky and cannot handle stainless steel- they are incredibly sensitive to it. Anyone?
We have a LOMA IQ4 model that has a "metal film" option under product type for items that are in foil packaging. Our product is in jars that are capped only after passing metal detection, so I'm not sure how well the metal film option works, but I can say it's a great metal detector for us. It even comes with auto-learn and built-in PVS that you can use to validate its performance as a CCP. We regularly pass our ferrous, non-ferrous, and stainless steel test pieces through with no issues regarding detection failure (100% reject rate for test wands).