7 replies to this topic

[Evez]

for the dry blending process wherein materials undergo sieving (OPRP0 and magnet trapping (OPRP) prior to packing. then passed bag thru a metal detector which is CCP.

 

auditor is questioning on why Metal Detector is considered a CCP.

upon passing thru the bag in MD, it does not reduced/eliminate hazard that is present in the bag.

 

however, we considered it as CCP as this is already the last step.

it may not reduced/eliminate the hazard present in the bag by the time it passed thru MD but it will inform us that the might contain a physical hazard. thus, we can remove it indirectly by getting the bag and do investigation.

 

can somebody enlighten me on this?

[Andy_Yellows]

I suppose from the auditor's point of view the sieving and magnet trapping are the CCP steps and passing the product through the metal detector is simply a monitoring exercise to test whether the sieving and magnet trapping have worked? That's how I'd have it myself but as you know these things are all in shades of grey.

 

Did the auditor merely question you on it or have they requested you reassess and update your CCPs? If they only questioned you to give you food for thought then it probably doesn't hurt to be challenged on something like that. If they requested that you change it then I wouldn't have thought it was their place to do that given that you've (presumably) been through the proper process in deciding which steps are and aren't CCPs and have good corrective actions in place in the event of a failure.

[Selena01]

If you are using the decision tree in the FSSC guidance document, take note that Question 4 have sub-questions that needs to be assessed:

 

For metal detector:

a. The effect on the hazard - MD does not eliminate/reduce physical hazards

b. Control measure specifically applied to reduce to acceptable level? - No; it's only there for detection

c. Any subsequent control measures? No; it's the last step

d. Single control measure or combination? - MD functions in combination with your sieving and magnet (in my opinion)

 

Most likely this will point you to OPRP.

 

Also, you mentioned that when a physical hazard is detected you can just remove it in the bag and do investigation. After you remove the physical hazard, what will you do to the bagged product?

 

This is only my opinion though, as I am still new to this. :) 

[Charles.C]

for the dry blending process wherein materials undergo sieving (OPRP0 and magnet trapping (OPRP) prior to packing. then passed bag thru a metal detector which is CCP.

 

auditor is questioning on why Metal Detector is considered a CCP.

upon passing thru the bag in MD, it does not reduced/eliminate hazard that is present in the bag.

 

however, we considered it as CCP as this is already the last step.

it may not reduced/eliminate the hazard present in the bag by the time it passed thru MD but it will inform us that the might contain a physical hazard. thus, we can remove it indirectly by getting the bag and do investigation.

 

can somebody enlighten me on this?

Hi Evez,

 

I deduce this is fssc22000 related.

Obviously a MD only removes magnetic metallic hazards. In fact it does remove such hazards within a defined size, orientation, magnetic Scope, etc.

 

I deduce yr hazard analysis concluded that various steps were Significant Hazards (SHs) for metallic fragments, eg necessitating sieving, magnet trapping, metal detector.

 

Accordingly, as per iso22000, you should have carried out an appropriate, detailed, ISO22000-based Procedure (ie not Codex) to allocate the SHs to either OPRP/CCP. IMEX this would have readily shown  the MD step to be a CCP (for metallic hazards).

 

So what Procedure did you implement and why was the Auditor not satisfied with it ?

 

PS - ISO22000 does also permit the use of a combined control measure but in this situation IMEX it is more "conventional" to regard the last step as "Critical". It can be a Grey area, some traditional Codex analyses regard both magnet and MD as CCPs.

Edited by Charles.C, 24 October 2022 - 08:29 AM.
added

[Evez]

If you are using the decision tree in the FSSC guidance document, take note that Question 4 have sub-questions that needs to be assessed:

 

For metal detector:

a. The effect on the hazard - MD does not eliminate/reduce physical hazards

b. Control measure specifically applied to reduce to acceptable level? - No; it's only there for detection

c. Any subsequent control measures? No; it's the last step

d. Single control measure or combination? - MD functions in combination with your sieving and magnet (in my opinion)

 

Most likely this will point you to OPRP.

 

Also, you mentioned that when a physical hazard is detected you can just remove it in the bag and do investigation. After you remove the physical hazard, what will you do to the bagged product?

 

This is only my opinion though, as I am still new to this. :) 

 

Yes, we're using the FSSC Guidance document  and this is what the auditor pointed out. that Q4 will have a "No" answer thus should be considered as OPRP.
however, during the discussion with our sister company's they don't agree to change to OPRP since MD is the last step.
i can't also change our own HACCP plan as this should be aligned with the regional site.
and i'm caught in between the auditor and regional team on which one is correct.

[Charles.C]

Yes, we're using the FSSC Guidance document  and this is what the auditor pointed out. that Q4 will have a "No" answer thus should be considered as OPRP.
however, during the discussion with our sister company's they don't agree to change to OPRP since MD is the last step.
i can't also change our own HACCP plan as this should be aligned with the regional site.
and i'm caught in between the auditor and regional team on which one is correct.

Hi Evez,

 

IMHO the Guidance Material regarding differentiation of CCP/OPRP is flawed.

Personally, I would ignore it.

[Evez]

Hi Evez,

 

I deduce this is fssc22000 related.

Obviously a MD only removes magnetic metallic hazards. In fact it does remove such hazards within a defined size, orientation, magnetic Scope, etc.

 

I deduce yr hazard analysis concluded that various steps were Significant Hazards (SHs) for metallic fragments, eg necessitating sieving, magnet trapping, metal detector.

 

Accordingly, as per iso22000, you should have carried out an appropriate, detailed, ISO22000-based Procedure (ie not Codex) to allocate the SHs to either OPRP/CCP. IMEX this would have readily shown  the MD step to be a CCP (for metallic hazards).

 

So what Procedure did you implement and why was the Auditor not satisfied with it ?

 

PS - ISO22000 does also permit the use of a combined control measure but in this situation IMEX it is more "conventional" to regard the last step as "Critical". It can be a Grey area, some traditional Codex analyses regard both magnet and MD as CCPs.

 

we're using the FSSC Guidance document for the decision tree. wherein Q4 will have a 'No' answer.

thus, auditor is pointing out the use of combined control measure.

 

i guess it's the confusion between the FSSC guidance and Codex.

[Charles.C]

we're using the FSSC Guidance document for the decision tree. wherein Q4 will have a 'No' answer.

thus, auditor is pointing out the use of combined control measure.

 

i guess it's the confusion between the FSSC guidance and Codex.

Hi Evez,

 

No, the confusion is between the FSSC22000 Guidance Material and other well-established Procedures specifically developed for ISO22000.

 

ISO22000 was never intended to be interpreted via a conventional Codex Tree Analysis albeit such Procedures have been used. Various dedicated Procedures exist for CCP/OPRP selection which afaik are usually auditorially acceptable but so far I have not seen any external review of the FSSC22000 reccommendations. Note that FSSC comment that other Procedures/Approaches can be utilized.

 

PS - it sounds like yr auditor feels obliged (same as you?) to stick with the FSSC Guidance material. Possibly unfortunate.

Edited by Charles.C, 24 October 2022 - 08:33 AM.
added