Risk assessment - Metal Detector vs. X Ray (foreign body detection)

Hi All

I’m doing a gap analysis for the requirements of a UK retailer, who is a customer of my client and I have noticed this requirement in their standards:

Where metal-detection systems are in place, there must be a risk assessment conducted to determine and define which detection system is the most accurate and appropriate for the product being made e.g. X-ray or metal detection equipment.

In common with most established food manufacturers the site already has metal detectors, not X Ray and there are no plans to invest in X Ray equipment.

Complaints of foreign bodies are not high (few reports of EVM, eg. pips/stalks and occasional metal issues, mainly from equipment, not raw materials). 

The site produces hot & cold fill sauces (some of which are sieved, some not, depending on particulate content).

My limited knowledge of X ray systems is that X Ray is affected by product temperature, requires more frequent calibration checks and is slower than metal detection.

To me the need for a risk assessment really is a moot point as the metal detectors are already in use and unlikely to be replaced.

My question is this – how do I go about producing a risk assessment for equipment that was installed quite some time ago and unlikely to be changed in the near future?.

Any suggestions gratefully received.

Honestly it sounds to me like your assessment will show you do not need an x ray machine due to sieving where needed, having metal detection, etc.

But you can't base it on:  we don't want to invest in it, or we already have a metal detector so no x ray is needed.

Do your due diligence and I think you'll come out with not needing one, but do it for the right reasons.