HACCP/CCP Opinions - Do I need more than 1 HACCP Plan?
Hi everyone,
We are considering implementing X-Ray technology into our operations as part of our QA/SQF Program. We are currently using metal detection, which we have classified as our CCPs. What we want to do is for 1 product we produce, is move that through X-Ray for QA rather than the metal detector. The process will still remain the same, run through the same line, but will move through the X-Ray machine rather than metal detector.
My question is - if we are keeping the processes, receiving raw materials, handling, etc the same as our original HACCP plan, with the exception of 1 product moving through an X-Ray machine instead of the metal detector, can I keep our original HACCP plan in place and just update our processes flow to reflect one product moving through this machine?
Thank you to anyone in advance that responds!
Yes you can
provided the x-ray does as good a job OR better at detecting your foreign material hazards as applicable to your process
Yes you can
provided the x-ray does as good a job OR better at detecting your foreign material hazards as applicable to your process
Thank you for responding, Scampi! From my understanding from techs we have spoken with, the machine will be as accurate, if not more, than our metal detector.
Would you suggest making a sub process flow for this 1 product or just adding it into our existing and specifying it is just for this one product?
Really appreciate you taking the time to respond!
I've gotten away with branching a flow chart due to a customer requirement before (but admittedly not for xray). Auditors are going to look hard at it, questions like "Why aren't you x-raying everything?" Make sure when you update the hazard analysis to add the xray step that you aren't calling out any additional risks to your own product/process that the xray is designed to handle.
Example: say you processed meats, and you identify the xray is supposed to catch bone fragments. Soon as the auditor reads that, he's going to ask why all your MD'd product isn't being xrayed if bone fragments are a risk.
I've gotten away with branching a flow chart due to a customer requirement before (but admittedly not for xray). Auditors are going to look hard at it, questions like "Why aren't you x-raying everything?" Make sure when you update the hazard analysis to add the xray step that you aren't calling out any additional risks to your own product/process that the xray is designed to handle.
Example: say you processed meats, and you identify the xray is supposed to catch bone fragments. Soon as the auditor reads that, he's going to ask why all your MD'd product isn't being xrayed if bone fragments are a risk.
i agree with JFREY 123
I don't see why you couldn't call the step "Metal Detection by metal detector or X-ray"
Just our of curiosity, why would you spend the extra money for an x-ray when a metal detector has historically been able to control the hazard / Risk?
Don't you have to expand on the rads?
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My question is - if we are keeping the processes, receiving raw materials, handling, etc the same as our original HACCP plan, with the exception of 1 product moving through an X-Ray machine instead of the metal detector, can I keep our original HACCP plan in place and just update our processes flow to reflect one product moving through this machine?
Thank you to anyone in advance that responds!
Yes. We use a single HACCP plan for a variety of products in the same category. Not all steps apply to all products. Including metal detectors on some packaging lines and x-ray on others.
As long we can describe the flow of materials from ingredients received to a finished good shipped out our inspectors/auditors have never had a problem with a branched flow chart.