Validation study to show metal detection is not required

Hello,

I am in the process of filing for a Variance with Tjs on their Audit 7.0 Metal Detection requirement. I need to submit a validation study that would support and demonstrate that this is not needed in our industry.  We pack whole watermelons, cantaloupes and pumpkins, this is not a standard in our industry. Any help would be greatly appreciated! 

Thank you in advance!!

Scabral 

How does your flow chart of the process look? You could show them your HACCP and see that in the entire process, no metal is introduced. Which is why you don't need it, it's not a risk introduced in your process.

Thank you for that suggestion.  They did go through our Haccp and still got me on not having metal detection devices. Its a requirement for them, unless i can get a Variance approved by them.  

Hello,

 

I am in the process of filing for a Variance with Tjs on their Audit 7.0 Metal Detection requirement. I need to submit a validation study that would support and demonstrate that this is not needed in our industry.  We pack whole watermelons, cantaloupes and pumpkins, this is not a standard in our industry. Any help would be greatly appreciated! 

 

Thank you in advance!!

 

Scabral 

Hi Scabral,

Unfortunately I have no idea what (or who) Tjs is ?

Regardless, yr options may likely depend on Tjs's specific related text and any (if available) Guidance material ? Perhaps you could upload/link such material?

As per Post 2, you probably need to post some details of yr existing Process stages to enable any useful opinions on yr "Validation" options.

For example BRC (British Retail Company as was) are strongly in favour of metal detection capability in a process line but will  nonetheless consider an exemption where the situation can be demonstrated as equivalent to Post 2. I recall that the USFDA [Seafood haccp manual] lists certain types of process equipment(s) whose presence  is regarded as a likely  significant source of  metal contamination in a finished product but also includes a specimen Procedure to enable avoidance of Metal detection equipment in an appropriate scenario.

Hello, indeed the BRCGC has a desition tree, where the last question is:

Is the product of a nature or usage such that any metal contamination would immediately and always be apparent to the customer and would consequently be removed before usage of the product? (e.g. unprocessed whole fruit and vegetables or primary cuts, carcasses of raw meat)

And in your case, the answer is “YES”, I asume,, then: “Metal detection not compulsory”

Hope this helps…

Leila

Tjs = Trader Joe's   (i'm guessing)

Yes, Sorry TJs = Trader Joes!! Thank you everyone for your help!!