I'll preface this that I haven't run juice, so my point may be moot if juice HACCP has more specific FM hazard requirements.
I've validated metal detector sizes on baked goods before using FDA guidance that 7mm or larger has had regulatory action taken against it for being injurious to human health (choking hazard). 7mm - 25mm. Reference: FDA CPG 555.425 Adulteration of foods with foreign material
It also specifies hard or sharp objects, and generally speaking paper or soft plastic bags are not considered hazardous to health under most circumstances (worse for company reputation) and I don't believe most regulatory agencies would insist on a recall for an isolated one-off paper/very soft plastic issue that isn't likely to be harmful to human health.
That may allow you to increase the size of your screen (potentially if that works with your pulp), possibly control with a magnet, or even control exclusively with pre-requisite programs and targeted inspections of health hazards that may fall in (like lights, glass, brittle plastic, knives used to cut bags, etc.) . Definitely would want to validate against screen records and customer complaints - if you are routinely getting findings then your screens are truly preventing hazards and you'll need to really figure out an alternative effective control. Inspections can be an effective alternative IF they are well designed and done by a reliable inspector and acted upon appropriately when there are findings.
Lastly - reach out to your equipment supplier if you haven't (whoever designed or sold the line with the screens) - they likely have worked with companies that package juice with pulp and may have some insight.
If you aren't having metal or hard plastic findings on your screens you have a pretty good potential case for the control not really NEEDING to be a CCP, but obviously need to tread extremely carefully.
Edited by Xoinks, 21 September 2023 - 09:09 PM.