7 replies to this topic

[joeysmith073]

Hello!

Im a brand new QA manager and I have my first SQF audit coming up in a few months.  One of the things my boss brought up during our internal was a risk score for the metal detection step in our process analysis.  Our previous manager scored it an 8 (high risk) for metal.  My boss gave the note that it poses no risk of introducing metal at that step in the process so it should be a low risk.  I know the previous manager so I asked him about it and he says we could really go either way.  Which option would be more correct? 

Thanks

[GMO]

What kind of matrix are you using?  There are several out there.

 

Are you arguing the severity is higher or lower or the likelihood or both?

[Tony-C]

Hi joeysmith073,

 

 

Welcome to the IFSQN forums.

 

There seems to be some confusion here, metal detection is a control measure used to reduce or eliminate a metal hazard to an acceptable level, therefore is likely to be low risk with regards to introducing a metal hazard. I’m not really sure what this process risk analysis is about.

 

The metal hazards will normally be (or should be) in steps prior to metal detection. So, you identify hazards and assess if they are significant and then decide on CCPs.

 

Explained as per CODEX HACCP Application Guidelines:

For hazard analysis CODEX Step 6/Principle 1, you are required to:

‘List all potential hazards that are likely to occur and associated with each step, conduct a hazard analysis to identify the significant hazards, and consider any measures to control identified hazards (CODEX Step 6/Principle 1)’

So, you will identify potential metal hazards at each step during your hazard analysis and any control measures.

Next you look at the hazards and ‘evaluate the hazards to identify which of these hazards are such that their prevention, elimination, or reduction to acceptable levels is essential to the production of safe food (i.e. determine the significant hazards that have to be addressed in the HACCP plan).’

Next is Step 7/Principle 2 Determine the critical control points (CCPs)

‘CCPs are to be determined only for hazards identified as significant as the result of a hazard analysis. CCPs are established at steps where control is essential and where a deviation could result in the production of a potentially unsafe food.’

To identify a CCP, whether using a decision tree or other approach, the following should be considered:

1. Assess whether the control measure can be used at the process step being analysed:

− If the control measure cannot be used at this step, then this step should not be considered as a CCP for the significant hazard.

− If the control measure can be used at the step being analysed, but can also be used later in the process, or there is another control measure for the hazard at another step, the step being analysed should not be considered as a CCP.

2. Determine whether a control measure at a step is used in combination with a control measure at another step to control the same hazard; if so, both steps should be considered as CCPs.

 

As you have posted in an SQF Food forum note that the SQF Food Safety Code requires:

2.4.3.1 A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines.

2.4.3.7 The food safety team shall identify and document all food safety hazards that can reasonably be expected to occur at each step in the processes, including raw materials and other inputs.

2.4.3.8 The food safety team shall conduct a hazard analysis for every identified hazard to determine which hazards are significant, i.e., their elimination or reduction to an acceptable level is necessary to control food safety. The methodology for determining hazard significance shall be documented and used consistently to assess all potential hazards.

2.4.3.9 The food safety team shall determine and document the control measures that must be applied to all significant hazards. More than one control measure may be required to control an identified hazard, and more than one significant hazard may be controlled by a specific control measure.

2.4.3.10 Based on the results of the hazard analysis (refer to 2.4.3.8), the food safety team shall identify the steps in the process where control must be applied to eliminate a significant hazard or reduce it to an acceptable level (i.e., a critical control point or CCP).

 

Kind regards,

 

Tony

 

[GMO]

It depends on how you define your hazard Tony.  The risk could be persistence of that metal hazard due to failure of the metal detection equipment but I agree, metal isn't introduced at that step and metal control is multi factorial. 

[Tony-C]

That would be risk of failure of a control measure GMO and not what the OP indicated.

 

Control measure: Any action or activity that can be used to prevent or eliminate a hazard or reduce it to an acceptable level.

 

A selection of Hazard Definitions here, perhaps you can explain ‘It depends on how you define your hazard’?

 

CODEX: Hazard - A biological, chemical or physical agent in food with the potential to cause an adverse health effect.

 

FDA: Hazard - Any biological, chemical (including radiological), or physical agent that has the potential to cause illness or injury.

 

BRCGS: Hazard - An agent of any type with the potential to cause harm (usually biological, chemical, physical or radiological).

 

ISO 22000: Food Safety Hazard - biological, chemical or physical agent in food (3.18) with the potential to cause an adverse health effect

Note 1 to entry: The term “hazard” is not to be confused with the term “risk” (3.39) which, in the context of food safety, means a function of the probability of an adverse health effect (e.g. becoming diseased) and the severity of that effect (e.g. death, hospitalization) when exposed to a specified hazard.

Note 2 to entry: Food safety hazards include allergens and radiological substances.

 

Kind regards,

 

Tony

[GMO]

And the hazard can be defined as failure of the control measures.  In fact it almost always is.  For example, inadequate cooking, insufficient maintenance.  In fact the control measure is almost always defined by the hazard, at least in part.

 

The PIGS approach is the way I was taught in how to structure a hazard.  "S" standing for survival (or persistence is often used where it's a foreign matter or chemical hazard rather than micro.)

 

Principle 1.1: Identify and list potential hazards | MyHACCP

 

The Campden training takes a similar approach to the above and it's in guideline 42 but that's copyright.

 

If a hazard has a risk of surviving or persisting a step then that absolutely is due to failure of a control measure.  Sometimes growth is too, e.g. failure of chilling or cooling equipment.

[Scampi]

It would be helpful if you could attached your actual risk matrix for your process to for us to be most helpful

[jfrey123]

My boss gave the note that it poses no risk of introducing metal at that step in the process so it should be a low risk.

 

Kind of an oversimplification on your boss' part.  Sure, a lot of MD's don't actually have a risk of adding metal to the product themselves (some actually do though).  But the point of a MD is that metal can be introduced to it from prior in your process, or your suppliers' process, and that metal is introduced at the MD step in your flow chart.  The MD exists in your flow to control metal from previous steps, so it's up to you to determine the likelihood and severity if the introduced metal is not detected and successfully rejected.  Hint:  using most risk matrixes, it's pretty severe and therefore a high risk.