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Can x-ray be a CP not CCP?

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TeemuH

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Posted 06 May 2024 - 01:17 PM

We are having BRC audit soon. I am asking your opinion as we have x-ray as CP not CCP. Our decision has been based on the fact that we are using x-ray in line where we detect foreign bodies in glass jars with metal lid. This means that only foreign bodies which can be found are metal pieces. We can not detect glass, ceramics, hard plastic etc. I.e. detection is not absolute one as you can get rid of only metal pieces. I our case can we keep x-ray as CP or not? Thanks in advance.



Scampi

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Posted 06 May 2024 - 02:00 PM

What do you mean you can only detect metal?? 

 

I'm confused    are you looking for metal with the x-ray or other types of foreign materials?   that's not how xray machines work


Please stop referring to me as Sir/sirs


G M

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Posted 06 May 2024 - 06:40 PM

We are having BRC audit soon. I am asking your opinion as we have x-ray as CP not CCP. Our decision has been based on the fact that we are using x-ray in line where we detect foreign bodies in glass jars with metal lid. This means that only foreign bodies which can be found are metal pieces. We can not detect glass, ceramics, hard plastic etc. I.e. detection is not absolute one as you can get rid of only metal pieces. I our case can we keep x-ray as CP or not? Thanks in advance.

 

 

A couple different answers to that:

 

Xray does not have to be a CCP, or a CP.  You can do it just for fun if you want to.  If, however, you identify foreign material as a risk factor, you're going to need some way of controlling it.  If you identify broken glass as a risk, you need to be able to control glass FM.

 

As Scampi implies, an xray can be used to measure the total absorption, and a chunk of broken glass inside the bottle should be measurably greater than an intact bottle if you have the right instrument for your process.  There may be some lower limit on how small a piece of glass can be detected, influenced by the consistency of the glass in your container, but it can certainly be done.  You aren't filling the container with something nearly as dense as the glass, right?



GMO

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Posted 06 May 2024 - 07:00 PM

I bet you if you did a bit of a search there are multiple threads on "is my metal detector / x-ray a CCP or not?"

You can argue it both ways.  BUT just because your x-ray isn't effective or validated against all foreign material, does that make it not a CCP?  I think that's what your question is asking.

 

Ok, my response is "no".  You define what your significant hazards are and presumably you've defined one as metal.  And for me, question 3 in the codex decision tree always makes me say "yes" to CCP on these kind of devices, i.e. "Is this process step specifically designed to eliminate or reduce the hazard to an acceptable level?"

(That assumes of course that you've not already decided the hazard is controlled by prerequisites.)

 

It doesn't mean glass isn't a significant hazard.  It might mean you control different foreign matter hazards in different ways, and that's ok.

 

Metal detectors and x-rays are odd ones in that they are a tool to control a hazard which is not 100% effective and in the absence of it working you would not say food is automatically unsafe (which in a way is pretty much what a CCP should be).  There are plenty of restaurant kitchens using a lot of industrial machinery but not having metal detection.  Is that unsafe?  But because of the sheer quantity of kit and difficulty in maintaining it to 100% in real high speed manufacturing, I'd be loathe to remove it.

Anyway, I'm being verbose.  The main point is, can you defend it?  The secondary point is, does it matter if it's a CP or a CCP on your controls?  If the answers are anything other than Yes and Yes, then make it a CCP.  

The older I get the more I get tired of fighting and more inclined to go with the majority view if it makes zero impact on what I'm doing.  If you'd control the hazard in the same way then is this the detail you should be spending your time on?  Or is it the fact that half of your staff probably aren't doing what at least one of your procedures tell them to do most of the time... (I'm guessing but I'm also pretty sure I'm right.) 

Basically, is this worth your energy?



tahoeskier

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Posted 09 May 2024 - 02:53 PM

If you are getting hits at X-ray for any foreign material, then that equipment is controlling a hazard. You also must look at customer complaints.

An auditor will issue an NC If they see foreign material detected in your x-ray log and it is not a CCP or Preventive Control. If you review CODEX decision tree, finding items at x-ray would warrant a CCP or PC.



Kiran

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Posted 15 May 2024 - 09:52 AM

Your question is can x-ray be not CCP, and I am not commenting on it.  But you mentioned that x-ray cannot detect glass or other contaminants than metal in glass jars.  X-ray system shoudl be able to detect glass in glass jars, though sensitivity will be lower compared to metal contaminants.  Glass is also a potential contaminant risk for glass jars packaging.





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