Risk Assessment for Not Using a Metal Detector in Cheese Production

We are cheese production company who have FSSC 22000 and going to be audited by version 6. We dont have any metal detectors but the external auditor who is going to do an internal audit in our site said that we need to do risk assessment in order to assure and show that we dont need metal detector. 

How does the risk assessment should look like? In HACCP plan we have covered physical hazards in every tehcnological step (included preventing measures and significance rate (severity x probability)). The significance rate in every tehcnological step is small - small enough to not be CCP. 

We have implemented glass and hard plastic everyday inspection, milk as a raw material goes through filters. 

Are you using wires to cut the large cheese blocks down?  If yes, not sure how you think you don't need a metal detector

Are you using wires to cut the large cheese blocks down?  If yes, not sure how you think you don't need a metal detector

Interesting observation Scampi - I've been in a lot of harping operations and most actually have two metal detection systems, one to protect their cutting equipment an that one detects the blocks and the other for the harp wires, which do sometimes cause the problem.

I don't think I've ever been in a cheese facility that did not have metal detectors or an Xray.

Hi LnMl,

:welcome:

Welcome to the IFSQN forums.

This falls under FSSC 22000 Additional Requirements Version 6 Section 2.5.11 Hazard Control and Measures for Preventing Cross- Contamination (All Food Chain Categories, Excluding FII):

d) For all food chain categories, excluding FII, the following requirements relating to foreign matter management apply, in addition to clause 8.2.4 (h) of ISO 22000:2018:

The organization shall have a risk assessment in place to determine the need and type of foreign body detection equipment required. Where the organization deems no foreign body detection equipment is necessary, justification shall be maintained as documented information. Foreign body detection equipment includes equipment such as magnets, metal detectors, X-ray equipment, filters, and sieves.

A documented procedure shall be in place for the management and use of the equipment selected.

The organization shall have controls in place for foreign matter management including procedures for the management of all breakages linked to potential physical contamination (e.g., metal, ceramic, hard plastic).

Unless your facility is unique, I would expect a high severity (possible serious injury) x high probability (wire breakage is common) = high significance. You should have metal detection or X-ray equipment.

Justification for not using metal detection or X-ray equipment is not going to convince many people but there would need to be a long history of no foreign body metal complaints, no related non-conformances and no history of wire breakage. Good luck with that!

Kind regards,

Tony

It will really come down to your initial hazard analysis. For example, the ratings you give for consequence and likelihood. You may have a low likelihood in your factory due to your unique set-up or equipment you use. Don't forget that metal detectors aren't the only control for metal objects. You can also have sieves, filters and magnets.

BRC has a decision tree for metal detection

The use of metal detector just reassures that all the measures taken BEFORE this stage are correct...

 On the other hand gives you an "online" detection procedure during the production.

Use of magnets are OK but you can check them two, three or four times per shift. This means that  you have a gap of two to three hours between checks. And if something goes wrong ... there is a big problem ... 

If you can confirm that there is no posibility of this cind of contamination you can go as before... But can somebody be so sure???