FSSC 22000 V6 Additional Requirement 2.5.11 Audit non conformance

Good day all.

I recently had our Food safety audit and got a non-conformance based off Add. Req. 2.5.11 non-conformance reads:

"At the time of the audit there was no risk assessment in place to determine the need and type of foreign body detection equipment required. The facility does not have specific foreign matter detection equipment in place and there is no documented justification for that either.''

Please help. Do I need to create a new risk assessment for this, or can I add it to our Hazard analysis? 

With regards to justification, we have never had any need for foreign body detection equipment. Our facility hand packs edible nuts, dried fruit and snacks, so there are constant visual checks at our packing tables. If anything is spotted, packing table stops and alerts production manager and from there a decision is made. We have no CCP's only PRP and OPRPs.

Control measures are in place. Is this enough to justify not having foreign body detection equipment?

Any feedback and assistance will be greatly appreciated. 

So do you rely on your suppliers for those checks then? You do need a risk assessment. 

I think you can do it in your hazard analysis, but if it's comprehensive enough, it's going to look like a risk assessment anyways basically.   Ours is done through the HA, but our HA is hard core and passes as basically a RA if it needed to stand alone, so auditor accepted that.   It just depends how you have it written up.

But if not, yeah, I agree with K.

So do you rely on your suppliers for those checks then? You do need a risk assessment. 

ok, I see what you're saying. Thanks! 

I think you can do it in your hazard analysis, but if it's comprehensive enough, it's going to look like a risk assessment anyways basically.   Ours is done through the HA, but our HA is hard core and passes as basically a RA if it needed to stand alone, so auditor accepted that.   It just depends how you have it written up.
But if not, yeah, I agree with K.

 I don't think our Hazard Analysis is that great if she didn't accept it. 

Thank you. I am new at this so I am still finding my feet with regards to Risk assessments. 

 I don't think our Hazard Analysis is that great if she didn't accept it. 

Thank you. I am new at this so I am still finding my feet with regards to Risk assessments. 

Each part of my hazard analysis is basically a stand alone risk assessment of that hazard, with a number ratings system of likelihood, severity, controls, etc.   It was a pita to put together in the front end, but it has paid off in the back end.   I'd say depending on your system it's worth the time to do it that way, but buckle up baby!   Lol.   It was a lot of work....