CCP missed for metal detection in packaging

Hello all, I have a question about a critical control point (CCP)/preventive control that was missed during a packaging run.

To be clear, this was a metal detection CCP, and two of the three test pieces were rejected properly. The third was not. In lieu of repairing the metal detector, confirming all three test pieces were rejected, and re-running all product through the metal detector, we inspected screws and bolts on the packaging line to see whether any were missing. Seeing none missing, we released the product.

1. Is it acceptable to handle a missed CCP like this? That is, is it acceptable that, in place of repairing the metal detector, confirming all three test pieces were rejected, and re-running all product through the metal detector, we had a different way of determining that no metal pieces were in the product?

2. If it is acceptable, then don't we need some comprehensive list of all screws we need to check for, and verify that's done, instead of simply saying we examined the machines and saw no screws missing. In other words, how detailed do we need to get?

I'm wondering how alarmed I should be that this CCP was missed and we released product anyway with this documented check.

We are regulated in the United States under 21 CFR Part 111 and 117 and we have SQF and NSF GMP certifications. 

Thank you,

Matthew

is that the procedure that your written documentation on metal detecting calls for?

But, then, what happens every time you run a check on the test piece and it fails to trip - do you have to do all this stuff instead of what the standards call for?

As an Auditor if i saw this as the correction, I' compare what was done vs. what the written documentation says is to be done and act accordingly - something tells me this would not be an acceptable thng considering that metal may possibly be introduced - then making sure all the bolts and screws are in place would not matter.

No, this is not what our procedure and written documentation on metal detecting call for.

I am lost. Where does checking nuts and screws come from?

And what was the third piece for? SS, Fe, NFe? 

Checking the screws and bolts on the packaging line was to verify that none were missing in lieu of meeting the CCP requirements; it was to verify that there were no metal pieces in the product. It was an attempt to perform the same function as the metal detector to verify that there was no foreign object metal in the product bottles.

I am lost. Where does checking nuts and screws come from?

The blue ferrous card 1.0 mm Fe passed through undetected.

And what was the third piece for? SS, Fe, NFe? 

IDK man. You are in trouble zone. 

Not acceptable.  Not acceptable at all.  But now I will get into split personality mode. 

In the heat of the moment, that was a stupid thing to do by whomever did it.  A metal detector doesn't just check for missing nuts and bolts but metal on metal swarf, damaged engineer equipment, something that has come in from an ingredient, deliberate contamination with metal, etc etc.

So far so not good.

BUT, you do have an upside.  The source of ferrous metal in your product, if it's there is unlikely to be your factory.  Most of your factory is stainless steel right?  So while it's not acceptable IN ANY WAY, the risk of harming someone is pretty low unless you have an ingredient which is possible to have some metal in there (e.g. root vegetables sometimes have bits picked up in the field but let's face it, stones will do as much harm.)

Does all of that make it right?  Nope, not even slightly.  And right now, I'd be having some bloody firm discussions with senior leaders on rechecking it (if it can be put back on hold) or even recalling it...  

But honestly, behind the closed doors of my mind, I'm not all that worried about that incident because if there is metal in your product then most metals you have will be detectable, what I'd be worried about is how it happened that the easiest to detect metal wasn't detected and what would happen if you don't call it back next time.  Lastly it's worth considering what it would do to your credibility if you don't kick up a mahooosive fuss about it. I've been in similar situations to this (not failing to check a CCP but leaving a product out where there was an incident I felt to be low risk), no explanation I gave satisfied people that it was low risk. We had zero complaints but still people felt I'd made the wrong decision and in some ways they're not wrong. I'd ruined my image in their eyes.

So with all of that, be careful of your own reputation and risk of regulatory issues but I don't genuinely believe there is huge food safety risk.