A Haccp Plan Without Metal Detecting Device

Greetings! I have been an avid reader of this forum for some time now and I have read most of the comments and suggestions on all of the problem posted.

Our company is into re-packing of milk powder and we are in the process of drafting a HACCP plan.

In our production process, the milk powder pass through a sifter, a horizontal auger, a hopper with a scrapper and a vertical auger (all metal parts) before the milk powder is packed into a pouch.

My question would be:
Do we need to install a metal detector in our line?
Can we have a HACCP plan without a metal monitoring device?

Many thanks,


Mark

Hi Mark, welcome to the forums, glad you decided to take the plunge. :D

I'll just throw a few ideas around before the experts take over.

 Are the machines maintained on a preventive maintenance schedule?
 Is there a documented pre or postproduction machine integrity check?
 Can raw materials be assured as free from contamination?
 Which metal parts could potentially contaminate - how big are they (choking hazard)?
 What about other non-metallic machine parts?
 Who are the intended users (children)?
 Have you ever had a complaint for metal contamination previously?
 If risk exist can this be controlled by measures other than through metal detection?
 What is the industry standard? I.e. do competitors metal detect - customer auditors should be able to tell you this.
 What is the HACCP teams expert opinion as to the likelihood and severity of metal contamination in your process?
 If metal detectors were free would you get one?

My gut feeling is that end of line metal detection will be required on top of other measures such as preventive maintenance and machine integrity checks.

Just a few thoughts to get us started.

P.S. don't forget to sign the guestbook.

http://www.saferpak....p?showtopic=620

Regards,
Simon

Hi Mark,

Above everything that Simon had us, all I really need to know is the intended use of the end-product.

The last time I did a HACCP Program for Milk Powder Facilities (surprising in the land of Malaysia) made re-pack milk products intended for animal feed and non-infact consumptions.

The answer to your question is actually very simple but the HACCP Program requirements itself apart from the metal detector is Big Time.

Regards
Charles Chew

Mark

From the information you've given I'm inclined to say 'yes' you do need a metal detector but you do need to go through the questions given by Simon. You have to assess the risks for your production line but given the number of moving metal parts, metal contamination could be a realistic hazard.

On a wider note it is perfectly possible to a have a manufacturing process and no metal detctor if you can logically justify this in the haccp plan i.e justify that there isn't a realistic risk of metal contamination occouring. I have done this but has been for smaller manfacturers.

Customers can and do override the risk assessment by insisting on a metal detector regardless of the risk of metal contamination, but that of course is another story.....

Regards

Ken

Dear Ken,

Your approach is realistic. As a matter of fact, since this is all about re-packaging, the crux of the issue is all about Supplier's Assurance Program. If the previous supplier/manufacturer can proof that metal detection had already been done and no other further process would render re-contamination in this area, a COA is sufficient to avoid metal detection requirements again.

Charles CHew

Mark,

I agree that metal detection is not essential to produce a safe product but just make sure you have data to back up this decision. From my experience I would like to add one extra thought to Simon's list...fitters tend to be the biggest source of unpredictable metal contamination; make sure that they, and other staff, are adequately trained to understand the risks.

...fitters tend to be the biggest source of unpredictable metal contamination; make sure that they, and other staff, are adequately trained to understand the risks.

<{POST_SNAPBACK}>

Yeah good point Yorky.

Perhaps it should be compulsory for all fitters to be given a handy hygiene training booklet or something to explain the risks. :P

BTW Yorky good to see you.

Regards,
Simon

Good point - maintenance program where fitters are involved may just leave "metal residue" behind. So how do we know that they did not "leave any metal residue behind when they are done " What if a crew was inadventently dropped into the "feeding tunnel" ..........can we avoid such a threat?

Can the re-packing equipment be dismantled for maintenance program, cleaned and put back? Or, will this become an issue with the auditor.

Hmm! interesting. The last time I did a HACCP program for re-packing of Milk Powders, the top "aluminium covers" were slit opened in a separate room then transferred down to filling room into the filling hopper............through a gyro vibrator sieve then ......into new kraft bags.......oops! no metal detector.

Cheers
Charles Chew