Costco Supplier Requirements – Alternatives to X-Ray for BRCGS Certified Facility?

Hello Folks,

Our facility is BRCGS certified. We are a supplier for Costco, which has specific requirements for the equipment we use in our production process. One key requirement is the installation of an X-ray machine to ensure that our products are free from contaminants. Currently, we have a metal detector in place, which helps identify and remove metal contaminants from our products. However, we are exploring alternatives to the X-ray machine due to budget constraints and operational considerations. I would appreciate recommendations for suitable alternatives that comply with Costco's safety standards. Additionally, I would like to know if Costco would accept these alternatives instead of an X-ray machine. Thank you for your assistance

If you can not as of yet afford to do so, I would highly recommend you write up a cap plan showing when you can lease or buy an X-ray system, you will need to actively look for a system, getting all the info on it etc and submit that with ownership/upper management sign off - there does need to be a - this will be done by such and such a date, etc.

With saying that we helped a long-time supplier to avoid a major finding on an SQF/Costco extension by proving they had (in effect) "grandfathered" his use of a metal detector due to the fact that for almost 20 years they have been supplying using a metal detector.

If memory serves me right they had actually purchased an X=ray system but based on the density of their frozen product it proved to be extremely problematic and thus without I think saying anything they went back to using the MD and had been passing all audits for years until a recent hitch, which is where we stepped in.

The thing is if you can prove that an X-ray is NOT needed, even though Costco does try to hard press this one then you can stay with your MD - but you will need an EXPERT to write a letter explaining why an X-ray (subject matter expert that is) is not suitable and that should remove the X-ray requirement - but this one is an extreme thing and not all are accepted by Costco - and finding someone to write one of these is quite the undertaking in itself.

1, What is your current product? What is the package size?

2, What is the hole size of the metal detector you are using?

3, What is the size of the metal test piece you are using?

The biggest advantage of X-ray machines over metal detectors is that they can detect non-metallic foreign objects, such as ceramics, glass, hard bones, and so on.

Of course they all still have minimum size restrictions.

X-rays may not be better or even worse if you're simply detecting metal.

If you already have a metal detector but still find metal, then:

1, Is your machine already working at maximum sensitivity?

2, Can you ensure that there will be reliable rejection of the metal if it is detected?

These tasks require particularly specialised technicians to perform and are almost impossible for the average user to do.

Frankly we are such an organisation and you can tell me the first 3 questions I'll make a brief judgement.

Of course, I'm also happy to answer any questions.

you need a cost/benefit analysis to see if the x-ray is worth the business

You could have a specialist (there is another thread on the how) to say the MD for YOUR PRODUCT is preferable to x-ray and why (exactly) in a professional report format   HOWEVER , Costco could still say to bad, put in the x-ray

They made it pretty clean in the vendor expectations rules that there isn't much, if any, wiggle room on this

The x-ray is required under the Foreign Material Control requirement for Costco suppliers. If you look at the attached FS&QAE guide for Costco Suppliers, it states the 3 allowable circumstances in which a supplier does not need to use x-ray (page 19).

 

All manufacturing operations must have a properly installed and calibrated X-ray detection device for

finished product, except in the following circumstances:

• Product texture, density, or chemical composition is such that it limits the performance of the X-ray technology to an unacceptable level. These operations will be required to have a metal detector installed as well as a letter from a subject matter expert confirming that Xray is not applicable.
• Shell Eggs, whole raw agricultural commodities, whole roasted coffee beans, whole muscle meats, and packaging products will be exempt from the X-ray requirement. The operation will need to maintain current good manufacturing practices and prerequisite programs to mitigate foreign material contamination.
• Operations that utilize a physical barrier (e.g. screen, filter, sieve) that's appropriately sized and placed will be exempt from the X-ray device requirement. The operation will need to conduct integrity checks at a defined frequency, and maintain current good manufacturing practices and prerequisite programs to mitigate foreign material contamination.

What I did at my previous place was write up what was basically a short research paper stating why x-ray was inappropriate for the product supplied to Costco and detailed the product properties and the production process, including citations.

Although I'm sure you could also easily get a short letter from the company that installed or calibrates your metal detector. A letter from them should be acceptable as the "letter from a subject matter expert" that the requirements state. I would have gone this route if I was not as experienced with the specific product type or process.

Food Safety & Quality Audit Expectations - 4.1.23 (1).pdf   556.67KB   13 downloads