Xray and HACCP plan update

Hello,

My facility just purchased Xray machine for RTE Not shelf stable deli meat. I need help writing the program and updating the HACCP plan. Only one line will be using X ray detector. Other lines will continue using regular metal detector. 

Thank you,

You have one HACCP plan that covers both lines and the metal detector is a CCP?

If you are changing your Hazard Analysis to indicate the x-ray is needed to reduce a FM risk other than metal,   both lines need to have an X-Ray

If you purchased the added protection of an X-Ray but there is no added risk of FM other than metal, label the step "metal detection (metal detector or X-Ray)"

If one line has a risk of FM other than metal (the one with the x-ray) and the other one doesnt, separate into 2 haccp plans.  

Does that work for you?

Me thinks kingstudruler hit with the nail on the head.  I'm going to bet one non-existent fake dollar that OP's plant is adding x-ray to satisfy a customer requirement, maybe someone that rhymes with Rostro.  If your PRP's and PC's are controlling FM but metal was the only hazard identified as needing a CCP, and that hasn't changed in your process or HA, then technically that x-ray is only there to detect metal.  The CCP does not dictate what hazards we scan for.  In my agreement with king, you'll want to ensure the x-ray can meet the same critical limits for metal FM as your metal detectors do, and they can then be listed in the same metal detection step in the HACCP flow chart and HA.

Now, what'll be interesting to monitor is whether the x-ray starts to hit on things you weren't expecting to find.  Could be that with its non-metal superpowers, you start finding rejections bearing non-metal FM's.  In which case, you'd have to wholly revisit your HA to discover where the non-metal FM is not being controlled and then update that that FM is being controlled at your x-ray CCP.  Which then means MD alone won't be enough for identical lines/processes.

Hi TruptiG,

I agree with kingstudruler1 & jfrey123, if you have put in that X-Ray Machine to comply with Costco requirements then it is only a minor change to the HACCP plan: metal detector or X-Ray to remove a metal hazard and I would note that the X-Ray is to comply with the Costco requirement.

The SQF Food Safety Code requires compliance with customer and regulatory requirements to supply safe food.

Costco: All manufacturing operations must have a properly installed and calibrated X-ray detection device for finished product, except …

If the X-Ray Machine is to control a different additional foreign body hazard then that means a separate but similar HACCP plan.

Kind regards,

Tony