RE: {Dubai's Food Safety Clinic} CCP or oPRP for Metal Detector

[Gordon Hayburn]

Why does either of them have to actually be a CCP?

 

From: foodsaf...@googlegroups.com [mailto:foodsaf...@googlegroups.com] On Behalf Of Vinit
Sent: Wednesday, October 07, 2015 6:50 AM
To: FSG Dubai
Subject: {Dubai's Food Safety Clinic} CCP or oPRP fro Metal Detector

 

Hi All,

 

If i have 2 metal detector in same line, first one for naked product (higher sensitivity) and second one for packed product (lower sensitivity). Which one is OPRP and which one is CCP? 

1st auditor: You need to use 1st MD as CCP and 2nd MD as OPRP /CP because 1st MD is the most sensitive and there is no further process that can eliminate the same hazard. 2nd MD is to eliminate metal from packaging and not product.

 

2nd auditor: You need to put 1st MD and 2nd MD as CCP because last MD cannot be a OPRP. The last MD is not sufficient to become CCP because the sensitivity is not enough and you need to upgrade to X ray.

The question is:- ??

1. Can OPRP placed after CCP point?

2. If the MD is intended for packaging only and act as precaution measurement, can we consider it as normal CP instead of OPRP or CCP.

 

Please share your thought. 

 

 Thank you.

Vinit Kumar 

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[Bobby Krishna Thulasi]

Vinit,

1.      I was not aware that auditors decide the CCP. Typically, it’s the responsibility of a competent Food Safety Team.

2.      If you are putting a metal detector at the end of your production line without analysis the risk of metal contamination in the raw material, process etc, then it should be called  ‘Damage Control’ and not a ‘CCP’ aimed at preventing problems.

 

 

Bobby Krishna T M                                                                        

Specialist

Food Inspection Section                                                           

Food Control Department

Dubai Municipality 

Mobile   :           + 971 554041340

Mail to: bkth...@dm.gov.ae

 

 

Expo 2020

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[Harish]

Process Owner is the one who decides which is a C.C.P and which is not and Auditor has no role in it. No hard feelings against auditors as such but both these auditors should be questioned.  In this example both the auditors has to first state whether the foreign body controls employed by the company is working or not. If they yes then ask them why both steps has to be a C.C.P and not C.P. If they say no then ask them to raise an NC on where the foreign body control could fail, correct it and then ask the same question again. We are not bringing in auditors to implement systems as per what they think is right. The process owners will conduct the hazard analysis and determine hazards and their controls and auditors are brought in to improve the systems and raise concerns which they can justify against relevant clauses with reasonable explanation.      

 

With Best Regards
Harish

[Abdulla KP]

Dear Food Safers,

We are not using any metal detector in our lettuce packing house, during our BRC external body audit yesterday auditor mentioned it as a NC and explanation given as it is a CCP only, because in this step you can stop the physical hazard or else you must have a declaration from your customers for not using it. 

Regards,

 Abdulla KP

Asst. QC Manager

 Mob: +97433818010

[Arsalan Zai]

Hi everyone

A very interesting discussion ....

Much has been already said about the audito's conduct so I will not comment on that. Now lets talk about the situation at hand:

After implementing control measures, PRPs and after doing proper hazard analysis; a metal detector step becomes a CCP because of following explanation:

The process step has control measure in place (Q1 of HACCP CCP decision tree = Yes). Also the step has been specially designed to eliminate or recude the occurence of hazard to acceptable level (Q2 of HACCP CCP decision tree = Yes). This scenario is the one which makes metal detector CCP. Because the reason a metal detector is installed is to only control/eliminate/reduce the hazard of metals passing by.

So this means almost every time a metal detector would be a CCP. But in the current situation there are two metal detectors. The way to go is this:

The first metal detector shouls be considered an OPRP on the bases that it has been installed only to control metals from going into the next process step and has no/less impact on final packed product (which is going to the consumer). The second MD should be more sensitive or at least equal in sensitivity as first MD. Now for second MD the logic is that since it has been placed in process to control the hazard and it is the last control befor product goes to consumer, it is a CCP.

I hope this explanation makes sense.

The person who is having this issue in their process can call me on following number to discuss further. 

Kind regards,

Arsalan Zai

Contact: 0551747802

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[Vinit]

Dear Abdulla,

So how to control physical (metal) hazard without metal detector u can't ensure that products free from metal contamination.

Either you can use magnet then lettuce passes through the magnet conveyor belt.

   

On Tue, Oct 13, 2015 at 11:31 AM, Abdulla KP <abdu...@gmail.com> wrote:

Abdulla KP (abdu...@gmail.com) added themselves to your Guest List | Remove them | Block them

[Saif]

Gents

Point1. if we are talking about Physical hazards

Every manufacturer does not have a scope to have a metal detector, if not required, and the logic is every metal detector is having a sensitivity above over the range it may not catch the metal. Irrespective of what is the standard critical limit , Metal is always hazardous in any form or size, the severity may differ. 

So if you justify that the point of foreign body source of contamination , probabilities and controls, No auditor can challenge for force-ably having which as a team you have decided. 

Point2. if we are talking about chemical contamination

Heavy metals in vegetables, this may take time to test and have a positive release, now it depends upon the operator to decide how the procedure must be followed for frequency and time based on the kind of vegetable.

Hope this may help out....

Regards

Saif