11 replies to this topic

[lavalienteQA]

Hi all,

 

As part of our process, we've begun implementing a sieving process for organic sugar received. 

Most, if not all pieces of foreign material (metal pieces) that are found are less then 7mm. 

All of this is done prior to production where sugar is then added and FG gets metal detected.

We have had a significant amount of product that was rejected due to these findings even after sieving.

 

We've gone back to the supplier with our concern but they have of course voiced their standard against FDA and that they meet the requirements.

 

They're 50lb bags we'd have to sieve through for hours at at time. Our supply chain is considering another vendor but I want to ensure I have my facts straight when I reply to this vendor.

 

Any opinions?

 

 

[MDaleDDF]

If I was finding metal like that in my sugar, yeah, they'd be gone.   We don't sieve anything, and I have MAYBE 20-30 kickouts a year on my MD, and at least half of those I can't find metal after shaking it out, and chalk it up to machine issue or metal inside the packaging.    And we run mostly 5 pound bags, and do around 20 million pounds a year, so that's a kickout number I'm pretty happy with.

I'd definitely be looking at a new sugar vendor.  

[lavalienteQA]

If I was finding metal like that in my sugar, yeah, they'd be gone.   We don't sieve anything, and I have MAYBE 20-30 kickouts a year on my MD, and at least half of those I can't find metal after shaking it out, and chalk it up to machine issue or metal inside the packaging.    And we run mostly 5 pound bags, and do around 20 million pounds a year, so that's a kickout number I'm pretty happy with.

I'd definitely be looking at a new sugar vendor.  

 Thanks MDale, I agree. 

When you did you numbers, did you do parts per million against any type of defect limit? Vendor is hitting me with the "Ya know foreign material findings are common in sugar". Totally understand, nothings perfect but I won't allow a recall for our negligence. 

I want to make sure I'm punching the right numbers here. 

[Scotty_SQF]

Worked once at a place where we did 50 lb. bags.  Had kick outs from MD once in a blue moon.  When we sieved, very rarely found anything.  I'd definitely push back on the supplier.

[kingstudruler1]

my opinion is that the 7-25mm standard is the dumbest and most abused guidance the FDA has ever published. 

 

Any food safety professional that uses it for an excuse should quit and go make pencils.   

 

1mm x 5mm shards or wires will cause injury.  3-4 mm chunks will break teeth.   The guidance also states that the rule is invalid for children, elderly, etc

 

 

they are correct in that sugar plants create tons of metal.   Miles of screw augers and bucket elevators that are decades old.   I'm not sure what "significant amount of product rejected" means to you.    However, it sounds like there is still a risk that might need further control by you or the supplier.   

[SHQuality]

In all the time I worked with sugar, I never had any sugar rejected for the presence of metal.

 

Common sense says that if the pieces are large enough to cause harm, the FDA standard is not sufficient to ensure safety and it is entirely reasonable to require stricter controls. We may get stuck into details, but the main point that led to all the regulations is that all food should be safe and legal.

 

So safe and legal should be your combined goal.

[MDaleDDF]

 Thanks MDale, I agree. 

When you did you numbers, did you do parts per million against any type of defect limit? Vendor is hitting me with the "Ya know foreign material findings are common in sugar". Totally understand, nothings perfect but I won't allow a recall for our negligence. 

I want to make sure I'm punching the right numbers here. 

Firstly, if foreign material findings are common in sugar, please don't tell my sugar supplier, because I've never had this issue, and we go through millions of pounds of sugar per year here, all in 50# bags.   I don't recall in my 14 years here ever having a foreign material issue that I could trace back to my sugar.   Indeed most to all of the metal findings I have are internal in origin and due to our machinery.   And my MD is cranked, so I'm finding stuff smaller than the FDA calls for.   If there's ANY metal in my product, I'm 100% confident we're getting it and it's getting thrown out.   I feed this stuff to my family, it has to be perfect.

 

As far as how I did my numbers, whut u talkin bout Willis?   I don't know what numbers you mean.   I just track kickouts, and findings of metal are tracked, graphed, over indulged, etc.   But I don't know what you mean by parts per million, etc.    If you clarify i'd be happy to answer.....

[Kara S.]

 Thanks MDale, I agree. 

When you did you numbers, did you do parts per million against any type of defect limit? Vendor is hitting me with the "Ya know foreign material findings are common in sugar". Totally understand, nothings perfect but I won't allow a recall for our negligence. 

I want to make sure I'm punching the right numbers here. 

 

That is the most insane thing I have ever read. They could be within specification for granulation size requirements, but there is no FDA requirement for size of foreign material! The requirement is for them to have a food safety plan that identifies biological, chemical, and physical hazard risks and control that risk. If they do not, then they (your sugar supplier) need to have a written agreement with your company stating that they identified this foreign material risk and they will not control it and you (your company) agreed to address this risk during processing. Read your contract - if its not there, it's on them and they should be sending you a new lot and reimbursing you for lost product. 

 

You should go to a new supplier and when you do, ensure your quality and food safety requirements are clearly spelled out in the contract - granulation size, no foreign material, color (white, no discoloration), and so on.  

 

The only issue I have ever had with sugar was occasional tanker lining flaking off from the railcars used to ship the sugar in. By the looks of it no one else here has any issues either. 

[Ryan M.]

Get a new supplier.  Regulatory requirements are bare minimum....the customer (you) can always require stricter requirements to ensure product quality and safety.  The fact you are rejecting and wasting product due to their issue is sufficient cause to find a new supplier if they are not willing to meet your requirements.

[G M]

Find a new supplier.  You can set a strict FM standard for what you are willing to purchase and not waste your time sieving ingredients.  It is highly probable that other vendors will be happy to accommodate your request.

 

We're going through millions of pounds a year in 50# to half ton containers and I can't think of a single root cause analysis that pointed to sugar as a source of metal FM.

[jfrey123]

They could be within specification for granulation size requirements, but there is no FDA requirement for size of foreign material! 

 

Most people are referring to this policy:  CPG Sec 555.425 Foods, Adulteration Involving hard or Sharp Foreign Objects | FDA, so indeed they have guidelines regarding size of foreign materials before they consider a product adulterated.

 

That said, I think it's a poor reply from the OP's sugar provider that they want to hide behind the 7-25mm guidance when addressing a customer complaint.  They can maybe argue that the FDA guidance deems it to not be adulterated, but it is absolutely a valid complaint that requires investigation per most GFSI codes.

 

The presence of the metal is unacceptable for OP's intended use, as proven by the need they have to sieve the product before using it.  If the manufacturer won't properly address the complaint, time to find a new vendor.

[Totes716]

We have metal detectors and x-ray machines in our facility and we use many different varieties of sugar.  At no point have we had any issues with metal particles dispersed in our product from the sugar.  I would be horrified and dump the supplier like a ton of bricks.