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Keep It Simple

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Posted 07 August 2018 - 08:52 PM

Hi All,

 

I am curious as to what function does a knife registry perform.

I've gone through all the different justifications but it just seems to be extra paperwork for no benefit.



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Posted 07 August 2018 - 09:04 PM

Hi All,

 

I am curious as to what function does a knife registry perform.

I've gone through all the different justifications but it just seems to be extra paperwork for no benefit.

In simple terms it helps you to keep an inventory of your Knives issued during a production run. It helps you to track that no knife is missing and to assure that the knife/knife piece did not end up in your finished product.

For example: if you issued 10 knives at the beginning of the run and you received 9 back at the end of the run, there is a hazard/possibility that the missing knife might be dropped in your production unit or FP.

Hope this helps..



Keep It Simple

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Posted 07 August 2018 - 09:36 PM

Thanks MIFSQN but we have metal detection and Xray in place to detect any metal.

 

I have had an auditor come through and they found a knife with a nick on the blade.Auditor said knife can no longer be used. Our pastry chef asked why not. Auditor replied that metal could end up in product. Chef replied that's what the detectors are for.

 

We use solid metal knives throughout and all detection systems are regularly checked and calibrated.

 

The only benefit we can see for a knife register is to identify a loss of an asset.

It provides no additional benefit to food safety.

 

Our goal is to reduce paperwork in food manufacturing by challenging procedures. I am QA born and bred but feel our profession is becoming its own worst enemy.

Food Safety is paramount but as we massage and manipulate manufacturers to a successful standard we allow some of our fellows to throw out some more "What If's" and generate more procedures.



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Posted 08 August 2018 - 12:49 AM

Hi, Keep it Simple.

 

Some points I don't agree with. It is "becoming its own worst enemy" because of the development of knowledge and people awareness (including consumers) over time. As food manufacturing, we always strive to deliver what is the best quality and food safe to our consumer and we do it by developing as much knowledge as we can to ensure that our process and recipe is safe as designed (as much as we would like to). Compromise can be made between the direction to "paperless" and what is currently realistically possible.

 

As for the metal detector (or Xray in any case), I always have this state during training that these devices should only be used to verify our control upstream as these devices have also it own limitations. What is currently happening is more resources and energy are given in management of monitoring system than what is given with the upstream control (which should be the opposite). If MD have detected something, it is more tiring to do investigation, and the cost of possible rejected batches.

 

On our case, while we also go paperless step by step, we use the knife registry to track knife movement including knife sharpening activity. If knife sharpening is not performed as plan, can deliver foreign material (such as plastics). 



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Posted 08 August 2018 - 02:02 AM

Always improving when new serious risks are found is what our mantra is.

 

I should state that the facility i am referring to is an industrial bakery with no high risk ingredients.

 

But I ask this, if a knife is returned damaged or not returned at all what are the steps.

To find the missing knife is definitely possible but a missing piece of a knife is not.

The procedures I've seen at some plants involve full line shut downs and multiple re-testing of products to ensure all efforts are made to locate the piece.

A complete waste of time and effort that was created by the existence of the register and the required procedures and documents that accompany it.

 

Retailers are introducing new standards at a frightening pace with little to no historical risk evaluation.

Sometimes even a knee jerk reaction to a ridiculous university study of bacteria on public benches or a baseless social media campaign about a suspected allergic response to some kind of food ingredient.

 

We're being asked to clean the tools used to repair machines even though the machines are thoroughly washed and checked after repairs. The reason: what if the machine wasn't washed and checked properly.

Staff must have captive shoes to work site even though they walk over areas where outside footwear has already travelled.

Wooden pallets are not allowed inside production even though they never leave the floor and are removed every day.

Staff must wash hands before putting on PPE and after PPE is on in case they contaminate their hands on the inside of the PPE.

We even ask visitors every time they come to the factory have they had diarrhoea in the past 48 hours even though hand washing is compulsory.

 

This list goes on and on and is mainly courtesy of a new standard from a major retailer in Australia which was a direct copy of Tesco's standard in the UK.

They are creating procedures to counteract if established procedures are not done correctly and have decided that there is no such industry as low risk.

 

I can testify that the manufacturing industry is rapidly losing all faith and trust in QA and treat our commitment to food safety with quiet and sometimes open hostility.

The dialogue with manufacturers is no longer transparent and is often convoluted and deceptive.

 

"What If" has become our new war cry and quite frankly we've only got ourselves to blame for this behaviour.

We're effectively telling manufacturers that they're not doing things right over and over and when they finally do it right we think of something else that they need to change.

We have become an industry more interested in growing our industry than simply protecting the consumer from "real" risks.


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Posted 08 August 2018 - 02:41 AM

In case of missing "knife" or any part of equipment, we have some risk-based approach and based on this approaced is we determine what we do in the product. What is also being drive by the registry is to make one accountable of possessing one, ensuring  the availability and of the right quality.

 

Should controls be based more on metal detector or Xray,I hope that there are not much of a complaint where the complaint being given is detectable by these devices. Too often, some complaints are being tagged as invalid due to presence of detection of equipment while the robustness of the equipment is not "fully" validated.

 

Standards needed to ensure fair trade. While, however, some auditors or QA professional gives you something to comply with based on what they know as "best practice" or their interpretation it suddenly is their norms but as long as what you have can mitigate or justify the risk present, then I think they (if they are open) may accept it.



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Posted 08 August 2018 - 06:37 AM

Always improving when new serious risks are found is what our mantra is.

 

I should state that the facility i am referring to is an industrial bakery with no high risk ingredients.

 

But I ask this, if a knife is returned damaged or not returned at all what are the steps.

To find the missing knife is definitely possible but a missing piece of a knife is not.

The procedures I've seen at some plants involve full line shut downs and multiple re-testing of products to ensure all efforts are made to locate the piece.

A complete waste of time and effort that was created by the existence of the register and the required procedures and documents that accompany it.

 

Retailers are introducing new standards at a frightening pace with little to no historical risk evaluation.

Sometimes even a knee jerk reaction to a ridiculous university study of bacteria on public benches or a baseless social media campaign about a suspected allergic response to some kind of food ingredient.

 

We're being asked to clean the tools used to repair machines even though the machines are thoroughly washed and checked after repairs. The reason: what if the machine wasn't washed and checked properly.

Staff must have captive shoes to work site even though they walk over areas where outside footwear has already travelled.

Wooden pallets are not allowed inside production even though they never leave the floor and are removed every day.

Staff must wash hands before putting on PPE and after PPE is on in case they contaminate their hands on the inside of the PPE.

We even ask visitors every time they come to the factory have they had diarrhoea in the past 48 hours even though hand washing is compulsory.

 

This list goes on and on and is mainly courtesy of a new standard from a major retailer in Australia which was a direct copy of Tesco's standard in the UK.

They are creating procedures to counteract if established procedures are not done correctly and have decided that there is no such industry as low risk.

 

I can testify that the manufacturing industry is rapidly losing all faith and trust in QA and treat our commitment to food safety with quiet and sometimes open hostility.

The dialogue with manufacturers is no longer transparent and is often convoluted and deceptive.

 

"What If" has become our new war cry and quite frankly we've only got ourselves to blame for this behaviour.

We're effectively telling manufacturers that they're not doing things right over and over and when they finally do it right we think of something else that they need to change.

We have become an industry more interested in growing our industry than simply protecting the consumer from "real" risks

 

Bravo! While the need for strict controls in any food handling area is obvious, it's getting harder and harder for me to disagree with people from other departments when they say a policy or procedure is 'a bit much'. I expect that many users of this forum with much more industry experience than I could justify just about any regulation or standard clause but as someone who has been involved in food safety for around 2 and a half years and still learning it already feels like the whole concept is disappearing up its own backside.


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FSQA

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Posted 08 August 2018 - 03:01 PM

I partially agree to few of your points and the frustration that have been created by some of the "auditors", when they think a process should have been done a certain way, which based on their experience from one industry (e.g Meat) should also be applicable to another industry (e.g Dry powder products). Certainly there are some common Hazards between both, but their will be specific Hazards to either of these industries. Therefore it depends on the risk assessment and risk mitigation in a case to case scenario.

 

I have seen multiple manufacturer's, that "DO Not" use an XRAY unit and only have Metal detectors at the end of the unit. While the product is processed through an enclosed chamber, magnets and a metal detector, there are chances of product contamination by the operator, right before final product packaging. So it can vary from one process to another.

 

Always improving when new serious risks are found is what our mantra is.

It should "ALWAYS" be a "Continuous Improvement" in a process. There will always be new Hazards introduced in a system, based on product/process changes or simply on the fact that new knowledge and research is introduced/shared related to a product/process. Think about who would have thought about " Bacterial resistance and Bacterial Mutation" few decades ago. 

 

 

 

But I ask this, if a knife is returned damaged or not returned at all what are the steps.

To find the missing knife is definitely possible but a missing piece of a knife is not.

The procedures I've seen at some plants involve full line shut downs and multiple re-testing of products to ensure all efforts are made to locate the piece.

A complete waste of time and effort that was created by the existence of the register and the required procedures and documents that accompany it.

Well, how would you feel if you would not be able to locate that missing piece/knife as a responsible QA and qualified individual and the finished product leaves your control to an end user?

I will be very cautious, not only because that knife was not located, but also of the fact that metal piece might end up in a customer's meal and a potential recall. Plants shut down lines to detect that piece not only part of a due diligence, but due to regulatory requirements (depends on the region).

 

 

"What If" has become our new war cry and quite frankly we've only got ourselves to blame for this behaviour.

We're effectively telling manufacturers that they're not doing things right over and over and when they finally do it right we think of something else that they need to change.

We have become an industry more interested in growing our industry than simply protecting the consumer from "real" risks.

"What If" should always be a part of one's proactive and Quality assurance process as it helps to mitigate a Hazard/risk.



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Posted 08 August 2018 - 07:15 PM

Keep it simple--forgive me, but I will be blunt

 

The fact that you have to ask is frightening. I've worked in a facility where CFIA is there ALL THE TIME......you do not have a regulatory choice---shut down and find (and I have, I have also condemned product) the broken piece.

 

Are you willing to guarantee that your "metal detector" will find a piece that is smaller than you test bars BUT also big enough to harm a child?

 

This is what our job is supposed to be!!!!!!!!!!!!

 

Metal detection is NOT a replacement for due diligence......if your "pastry chef" is ok using knife with chips (even though delicate breads/rolls etc won't like it) then they need to get out of your facility. 

You must inspect knives for damage at pre op and sanitation and any point in between (dropped, banged)......what if the metal detector fails? are you willing to bank roll the company because you decided the risk wasn't worth the 5 minutes a day and they had to recall because someone got cut on your baguette?

 

HACCP 101---eliminate/reduce/prevent hazards. Period

 

 

Now, having said ALL of that and coming from a federal inspected background where the law is the law.....there are a lot of auditors doing a really poor job, and given the way the process has been set up to turn folks into auditors, it's no big surprise, so yes, we all need to push back a little, but if you think we're the only industry where lobby groups and the public at large are dictating policy you are sadly mistaken


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Keep It Simple

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Posted 09 August 2018 - 07:48 PM

Sorry people, still not convinced.

 

I've been in this game for far too long and have heard the rhetoric of "what if a child" far too many times.

Over my career having reviewed 1000's of customer complaints you become immune to the catch cry of lucky a child didn't eat it.

My time in this career is coming to it's natural end as i rapidly approach retirement.

 

If detection systems are working correctly then the metal will be found during the course of production. If it is not found it either never made its way into the product or it is so small it could not be detected.

Small enough not to be detected then no harm to anyone is present. I have tried many many times to get metal through a calibrated metal detector and the best I've done is metal dust.

Detection systems not working correctly then all product is on hold until it can be checked again. Xray machines are quite frankly useless for most of our applications but we have them to put on a nice show for visitors.

 

Also i must respond about the bacterial mutation comment from FSQA which is entirely our fault for the overuse of chemicals from an incessant desire to kill everything whether it be good or bad. 

 

Scampi & FSQA I am challenging the entire evolution of QA and not just a simple knife register.

The more rules and changes we make the more opposition we create to the point where common sense goes out the window.

This is relevant in all parts of society. The more law enforcement and harsher penalties creates an environment of stronger opposition and a dwindling level of support.

 

Our industry is made up of:

  • Creators (What If's). The people who think of new potential risks. Generally very high up the food chain and have had minimal hands on time in industry.
  • Validators. People who respond to the creators and turn these new risks into standards. Creators henchmen who believe the propaganda fed to them. Save The Children.
  • Teachers/Enforcers. People who have to apply the new standards and enforce them on industry. Lowest paid, highly educated, hardest working and cop the most crap from everyone for standards they didn't create and often don't fully agree with.
  • Auditors. People who hold the Teachers/Enforcers accountable for the behaviour of the business they work in. Generally extremely well paid. Extremely well educated. And extremely wasted on what they do.

 

I have never heard of any product recall or withdrawal where a company has been following even basic HACCP rules. Ever!!!

It doesn't matter what standard number this year's guide is the fact remains that only when rules are broken, deliberately or not, you will present a risk to the consumer.

The more rules we have the more chance of the "deliberate" act coming in to play.

 

I still have copies of 9 different food standards all issue #1 and there is absolutely nothing wrong with them to this day. Imagine if the goals hadn't been moved for 35 years.

Every business would be kicking goals in their sleep and our industry would have the respect it deserves.



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Posted 09 August 2018 - 08:07 PM

I will say this KIS, i do NOT like these 3rd party audit schemes......the focus is entirely on the wrong thing. I've been in the industry for 20+ years across almost every commodity

 

Case in point-----food defense...........didn't realize the entire world needed to change for 1 countries view on terrorism....IMHO of course.........

 

I believe the problem(s) started when industry started to police themselves.......we all know regardless of industry, this is a really bad idea

 

The very notion that these audits have been born from RETAILERS and not science or even consumers is a thorn in my paw. I concur 100% with your ranking of how we fit. The vast majority of companies are always doing the right thing, even when issues arise, they are dealt with promptly and correctly.

HOWEVER, having read posts on this site from folks without much experience/age who clearly do not understand what they are talking about makes me think the audits may have a place after all (still thinking about running laundry detergent through food piping "shudder')

 

To your point re: recalls when even basic HACCP has been followed, I refer you to the recent Canadian salmonella breaded chicken recalls........you cannot cook chicken in the microwave and have it evenly cooked and I personally do not want to eat chicken that has been so chemically treated as to render it bacteria free. I have worked for the company who produced this product....everything is above board.  

http://www.inspectio...6/1527975835551


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Posted 09 August 2018 - 08:30 PM

Agreed Scampi.

Especially on the terrorism but the fault in that lies squarely at the feet of global media. Now there's a pack of hungry dogs gnawing away at the same bone.

 

Was the recall due to chicken being required to be microwaved from a frozen or fresh raw state.

Not a good idea at all but not HACCP related from a manufacturing point of view.

This sounds like some developer/marketer asking for the impossible to become possible to make a sale.

 

Salmonella is naturally present in Chicken so a recall due to the presence is not quite correct.

The recall is due to incorrect cooking instructions.



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Posted 09 August 2018 - 09:27 PM

I will say this KIS, i do NOT like these 3rd party audit schemes......the focus is entirely on the wrong thing. I've been in the industry for 20+ years across almost every commodity

 

Case in point-----food defense...........didn't realize the entire world needed to change for 1 countries view on terrorism....IMHO of course.........

 

I believe the problem(s) started when industry started to police themselves.......we all know regardless of industry, this is a really bad idea

 

The very notion that these audits have been born from RETAILERS and not science or even consumers is a thorn in my paw. I concur 100% with your ranking of how we fit. The vast majority of companies are always doing the right thing, even when issues arise, they are dealt with promptly and correctly.

HOWEVER, having read posts on this site from folks without much experience/age who clearly do not understand what they are talking about makes me think the audits may have a place after all (still thinking about running laundry detergent through food piping "shudder')

 

To your point re: recalls when even basic HACCP has been followed, I refer you to the recent Canadian salmonella breaded chicken recalls........you cannot cook chicken in the microwave and have it evenly cooked and I personally do not want to eat chicken that has been so chemically treated as to render it bacteria free. I have worked for the company who produced this product....everything is above board.  

http://www.inspectio...6/1527975835551

 

Showing my ignorance here, but I have never viewed Food Defense from that angle before. Wow!! Really changes my perspective.  





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