How to Score Metal Detection CCP in Hazard Analysis: High or Low Risk?
I have completed my Risk Assessments using the following rating scale:
(1–3 = High Risk, 4–15 = Medium Risk, 16–25 = Low Risk).
While conducting the Hazard Analysis for processes, should Metal Detection be:
- Rated in the High range (1–3) since it is our Critical Control Point (CCP)?
OR - Should all other processes be rated in the High range, and Metal Detection in the Low range, since the product passes through the metal detector only after it is already in primary packaging?
You might be going about the process backwards.
If the steps prior to the metal detector indicate a high risk of metal comtamination (liklihood and severity), the metal detector would be a CCP/PC.
Are you creating a HACCP or preventive controls plan? - since in USA. Or are you USDA?
In the example they have the risk high at the MD step as well as other steps where metal could be generated. YOu could also add your risk "number" to the form as needed.
see example for PC.
Attached Files
I am updating the Hazard Analysis with Severity and Likelihood for each process steps. Metal detection process in itself has a low chance of getting metal in the product. So likelihood should be low. While it is a CCP to control all other previous processes steps which can bring contamination.
...
While conducting the Hazard Analysis for processes, should Metal Detection be:... in the Low range, since the product passes through the metal detector only after it is already in primary packaging?
Automated detectors are usually about as risky as a conveyor belt ( minimal parts, little physical interaction with the product). The risk presumably exists in earlier steps.
I am updating the Hazard Analysis with Severity and Likelihood for each process steps. Metal detection process in itself has a low chance of getting metal in the product. So likelihood should be low. While it is a CCP to control all other previous processes steps which can bring contamination.
You're correct the MD is probably low risk in of itself for contributing metal contamination to sealed packages.
However, each step of your HA can have multiple scenarios and one of the scenarios you need to list under the MD step is metal contamination from prior processing steps. You've likely identified previous steps which may add metal contamination and referenced a MD step later in your flow as the justification for not controlling the metal hazard at that step. So next is to determine their likelihood those steps contribute metal (hopefully low likelihood), but for severity I would dare suggest it is high severity if the MD fails to perform as expected.
Thank you. I had the same thought — in case of a malfunction of the metal detector, it would be a serious hazard. You added a great point about the possibility of metal contamination from prior processing steps.
The same logic applies to the baking step: Baking itself is a low-risk process; however, biological contamination from prior processing steps would have high severity.