9 replies to this topic

[#AllergenSafety]

Hello,

 

I am a recent graduate and I started working for a GF/ Allergen free company as soon as I finished my masters so I have a lot to learn in this field.

I am rewriting the HACCP for one of our site that is a GF bakery. We previously had 3 CCPs the last one being the metal detector. Now we want to remove it and and only have 2 CCPs that is inspection of incoming raw materials and the freezer temperature. I was wondering if that's possible? Can we remove metal detector from the site and somehow prove in our pre-operational checks that foreign object contamination has been prevented and controlled?

Moreover, I was thinking if we can make slicing (the bread loaf) as a CCP instead of having metal detectors.

 

[Charles.C]

Hello,

 

I am a recent graduate and I started working for a GF/ Allergen free company as soon as I finished my masters so I have a lot to learn in this field.

I am rewriting the HACCP for one of our site that is a GF bakery. We previously had 3 CCPs the last one being the metal detector. Now we want to remove it and and only have 2 CCPs that is inspection of incoming raw materials and the freezer temperature. I was wondering if that's possible? Can we remove metal detector from the site and somehow prove in our pre-operational checks that foreign object contamination has been prevented and controlled?

Moreover, I was thinking if we can make slicing (the bread loaf) as a CCP instead of having metal detectors.

Hi Daman,

 

The selection/designation of CCPs is determined by hazard analysis/risk assessment, for example as detailed in Codex HACCP.

 

You may need to do some further studying on above topics as utilised in HACCP.

[Tony-C]

Hi Daman,

 

 

Welcome to the IFSQN forums.

 

I don’t see how you can suddenly decide that metal detection is not a CCP unless you have completed revamped your HACCP System and decided there is a better method of preventing foreign objects in your finished product.

 

Even so, removing the metal detector may be frowned upon. As an example, here are the requirements of the BRCGS Global Standard for Food Safety Issue 8: Section 4.10.3 Metal Detectors and X-Ray Equipment

Clause 4.10.3.1

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).

 

Previously I have defended not having a metal detector based on historical complaint levels but BRC changed the requirements of the standard and complaints alone cannot be used to justify not having a metal detector.

 

BRCGS Global Standard for Food Safety Issue 8 Interpretation - Requirement for metal detection

The Standard presumes that metal detection provides improved protection for customers and should form part of the food protection system of a site. Its absence would normally only be based on the use of an alternative, more effective, method of protection (e.g. the use of X-ray, fine sieves or filtration). There will, however, be situations where metal detection does not, on the basis of risk assessment, provide any significant additional protection to the consumer.

Where metal detectors are not used, a risk assessment must be available to justify the reasons why. While complaint levels are a factor in making a decision on the necessity for a metal detector, this evidence alone will not be sufficient justification for not using one. (For example, there may be instances of contamination which have not been reported by consumers.) Any justification for the absence of metal detection should be based on the nature of the product, the risk to the consumer, and alternative controls in place at the site which prevent metal contamination. Cost alone is not sufficient reason.

 

Kind regards,

Tony

[Scampi]

Agree with PP

 

and would also add---why would you remove a control measure at all?  The money is already spent and it's already a functional part of the process--IMHO this would be a step backward 

 

You would have to justify it's removal which is going to be difficult, unless you're planning on replacing it with x-ray

[MDaleDDF]

Short easy answer:   No.  

How is slicing the bread a ccp?

 

And if the slicer has metal in it, you need a metal detector.

 

[Kara S.]

Hello,

 

I am a recent graduate and I started working for a GF/ Allergen free company as soon as I finished my masters so I have a lot to learn in this field.

I am rewriting the HACCP for one of our site that is a GF bakery. We previously had 3 CCPs the last one being the metal detector. Now we want to remove it and and only have 2 CCPs that is inspection of incoming raw materials and the freezer temperature. I was wondering if that's possible? Can we remove metal detector from the site and somehow prove in our pre-operational checks that foreign object contamination has been prevented and controlled?

Moreover, I was thinking if we can make slicing (the bread loaf) as a CCP instead of having metal detectors.

 

 

Hi Daman,

 

The selection/designation of CCPs is determined by hazard analysis/risk assessment, for example as detailed in Codex HACCP.

 

You may need to do some further studying on above topics as utilised in HACCP.

 

 

To add Charles comments...

 

You really need to review your HACCP plan and determine where you have identified metal within your process and how you have been controlling it. If the answer has been you are controlling that metal hazard using metal detection then, no you cannot simply remove the metal detectors as a CCP. But, as an example, if you are saying, we identified our incoming flour as a risk and we use sifters and bullet magnets to prevent that risk, then that is an alternate control measure for metal. And if you review your HACCP plan and find that you have a control measure that is not metal detection for each of these metal hazards you identified and justify that a CCP was not needed at those steps, then you MAY be able to remove it. 

 

I do not know your process - but I have seen metal come from unexpected places in bakeries including pans, overhead elements, and the slicer as you mentioned. And what alerted us to those issues? The metal detector! I do not think it wise to remove them. Like Scampi mentioned - if you already have them why remove it??? Use it as a verification at least if you have other control measures. 

[Rick Reyes]

In certain cases of a very simple process flow I can see not having a metal detector because the risk really is not there or at such a level that it does not represent a risk to life or injury which is the real goal. I know that I tend to simplify things but usually the simplest answer is the best, while it is great to have the knowledge of where the specific regulations are and how they apply it also pays greater dividends to speak to your audience in a language that they will understand, if you speak above their heads it won't be any clearer to them than  it was before you explained the process. I have been working in the food processing industry since 1984 and in my time I have seen all kinds of things happen that make a person shake their head. While checking the ingredients is a good start in my experience 90% of the metal contamination occurs in house. Every manufacturer pushes the limits on their equipment to get the most life out of each bearing, or other metal part and when they fail the blame game starts. At the end of the day our responsibility is to ensure that the products we produce are safe for our customers to consume and that we took the necessary steps to ensure that this happens on a minute by minute day by basis.

[Brothbro]

Is your process being changed to such a degree that metal contaminants are no longer a significant risk? And if not, do you have an alternative control measure that would be as effective as a metal detector (doubtful)? As others have mentioned, the metal detector is already purchased and implemented in the process. It would be quite hard to justify why moving backward like this would be ok. 

 

Foreign material risk is very difficult to control with pre-operational checks alone. This is why in leu of metal detectors, facilities may opt for screens/sieves/filters to control contamination. Along with metal detectors, these control steps have the advantage of sifting/inspecting 100% of the batch. However, it sounds like you use metal detectors on your finished product. In this case, screens/sieves would not help.

[Philips]

 

 

My thoughts are there should always be the basis for determining a control measure as whether it's required and / or not required. What is the rationale of removing a control measure from the processes? Because, its not determined mechanically that we need a control measure as a process step, its determined through taking the process step through a HACCP decision tree.

 

It's also important to note in some instances, metal detector can be an oPRP and not a CCP. Having sadi that though, the one at the end of the processing for the end product can and will always be CCP. What definition do you give to CCP. I do it simply by saying its a control point of a hazard whereby if its not reduced and / or eliminated, it will reach the consumer, since there is no subsequent process step that can either remove / reduce it to acceptable levels

[Charles.C]

My thoughts are there should always be the basis for determining a control measure as whether it's required and / or not required. What is the rationale of removing a control measure from the processes? Because, its not determined mechanically that we need a control measure as a process step, its determined through taking the process step through a HACCP decision tree.

 

It's also important to note in some instances, metal detector can be an oPRP and not a CCP. Having sadi that though, the one at the end of the processing for the end product can and will always be CCP. What definition do you give to CCP. I do it simply by saying its a control point of a hazard whereby if its not reduced and / or eliminated, it will reach the consumer, since there is no subsequent process step that can either remove / reduce it to acceptable levels

 

Hi Phillips,

 

^^^(red) - From a haccp POV, the basic rationale for implementing a control measure  is the identification of a significant hazard. And contrariwise.

 

However for "Metal", the decision as to safety "significance" can be distinctly subjective.

.

(The well-known 1997 Codex Decision Tree was designed to particularly "facilitate" the handling of metal contamination).