Metal Detector Requirement for Strawberry and Blueberry Packaging

Hmm, interesting question.  I've never worked in produce but how I would approach it would be by risk (before you even think of BRC).

Is there a risk of metal in the strawberries or something being damaged in your process?  Is the picking by hand?  Is any of it automated at all?  Presumably the flow wrapping of the trays may be but with limited risk?

Are consumers likely to consume the product without thoroughly inspecting it?  It's possible. 

That said, metal detectors are pretty cheap nowadays.  So I would be inclined to say "yes" and get one anyway if I could.  

As for BRCGS.

Section 4.10.1.1 requires you to do a risk assessment for the potential use of equipment for removing foreign material, not that you have to have a metal detector.

That said, the interpretation guideline is pretty much written as though "yes you will have at least a metal detector" not "there are times you may not need one" (it's worth having a read, I expected it to list occasions when it may not be needed.  It doesn't do anything like that.)  The older versions of the standard were much more flexible about it from memory.

I think in summary it's possible to not have metal detection, especially where it's for a food which a consumer shouldn't be eating without cleaning it themselves (although you know "shouldn't" is doing a lot of heavy lifting there).  So can you get away with it?  I think it's possible but I'd make sure that risk assessment is SUPER robust and I'd consider it anyway because it's probably good practice if you have any level of mechanisation.  

All I can think about is the Strawberry Tampering Incident in Australia. 

All I can think about is the Strawberry Tampering Incident in Australia. 

That crossed my mind too.  I'm not sure they ever found the culprit though as the prosecution was dropped against the supervisor?  My thought was it could have been post site contamination (which would be possible with needles) and possibly more than one person.  But it's a good point that deliberate contamination is something which should be considered as part of your food defence / taccp plan.

All I can think about is the Strawberry Tampering Incident in Australia. 

All I can think about is the Strawberry Tampering Incident in Australia. 

Hi,

Thanks a lot stf, 

Interesting  document. 

I will be grateful  if  you could  share  a  HACCP template  plan  for  fresh strawberry  product. 

Best Regards

GMO has good points. Your product itself may not be risky, but the process it undergoes from farm to consumers may have something to consider. I would get one if feasible. 

Hi, 

Does anyone have a complete HACCP study template for fresh strawberry packaging (including the  flowchart)?

Hi MOURADTALBI,

As GMO posted this requires a risk assessment and will depend on the amount of handling the fruit gets from farm to pack and the risk of metal contamination.

The standard states:

The absence of metal detection would only normally be based on the use of an alternative, more effective method of protection (e.g. use of X-ray, fine sieves or filtration of products).

From BRCGS Guidance:

There will, however, be situations where metal detection does not, on the basis of risk assessment, provide any significant additional protection to the consumer; for example, where whole pieces of fresh produce (e.g. potatoes) are being washed and packed, and any metal contamination would be obvious to the consumer prior to consumption.

So you may get away with not having a metal detector if you are packing whole fruits but you should understand that you will fail your certification audit if you fail to convince the auditor that based on risk you don’t need one.

Kind regards,

Tony

Tony, I was looking for that section but must have missed it.  Thanks for finding it.  That's exactly what I was expecting to see.

 

From BRCGS Guidance:

There will, however, be situations where metal detection does not, on the basis of risk assessment, provide any significant additional protection to the consumer; for example, where whole pieces of fresh produce (e.g. potatoes) are being washed and packed, and any metal contamination would be obvious to the consumer prior to consumption.

 

Hi, 

Does anyone have a complete HACCP study template for fresh strawberry packaging (including the  flowchart)?

Your plant is not going to be the same as someone else's. Sticking a template in your risk analysis won't truly consider the risks your product is subjected to.

We know nothing about the supply chain or the legal standards these strawberries have to pass either as you didn't specify a location/country.

A HACCP study for packaging strawberries will include risks caused by:

1. pesticides, herbicides and fungicides,

2. microbiological contamination

3. physical contamination (metal from the soil or broken machinery, rocks, glass, brittle plastic, plastic from packaging, etc)

4. chemical contamination (other than those in bullet 1)

5. intentional contamination and adulteration (food defense)

6. contamination by pests (during growth, harvest, storage or packaging)

7. contamination by allergens

8. poor temperature control

I'm sure I've missed some risks in this list. The best way to write a HACCP plan to is to walk through the entire process from start to finish and list all the potential hazards you come across, then specify if those potential hazards pose a real risk, and if so, how to manage that risk or take away the hazard.

I would always get a metal detector to manage this particular hazard even if not doing so is an option. The alternatives to manage this hazard are labor intensive and a lot more expensive and error-prone in the long run.

Hi MOURADTALBI,

 

As GMO posted this requires a risk assessment and will depend on the amount of handling the fruit gets from farm to pack and the risk of metal contamination.

 

The standard states:

The absence of metal detection would only normally be based on the use of an alternative, more effective method of protection (e.g. use of X-ray, fine sieves or filtration of products).

 

From BRCGS Guidance:

There will, however, be situations where metal detection does not, on the basis of risk assessment, provide any significant additional protection to the consumer; for example, where whole pieces of fresh produce (e.g. potatoes) are being washed and packed, and any metal contamination would be obvious to the consumer prior to consumption.

 

So you may get away with not having a metal detector if you are packing whole fruits but you should understand that you will fail your certification audit if you fail to convince the auditor that based on risk you don’t need one.

 

Kind regards,

 

Tony

Thanks tony,insigthful  clarification. 

Kind Regards,