In my humble opinion as an Auditor I would have a ton of questions about
the validity of that process (hand held). I would not consider it a valid
method to ensure metal above specified limits (FDA, Spec, ect) is kept out
of product.
Conventional methods pass the product through a calibrated, verified
channel that has been set to a products specific density, temperature, and
other characteristics. It is verified and human error for the most part is
removed. With hand held it has no validity. If hand held metal detector
was a plants control under HACCP for metal inclusion I would say that it
will not ensure that metal does not get through. There are many ways to
address metal inclusion without using metal detection at all e.g.
inspecting blades at specified intervals. Bottom line is that hand helds
will only give a false sense that a hazard is being addressed.
Greg Scher, CQA
Pamela Tom
<pdtom@ucdavis.ed
u> To
Sent by: Marcelo Hidalgo
owner-seafood@ucd <marcelhi@yahoo.com>
avis.edu cc
Seafood HACCP Discussion List
<seafood@ucdavis.edu>
06/16/2005 09:58 Subject
AM Re: Metal detector
Hi Marcelo,
Thank you for mentioning the U.S. Food and Drug Administration's
"Fish and Fisheries Products Hazards & Controls Guidance." The third
edition (June 2001) of the Hazards Guide states the following about metal
fragment sizes:
"FDA's Health Hazard Evaluation Board has supported regulatory action
against product with metal fragments of 0.3" (7 mm) to 1.0" (25mm) in
length. See FDA Compliance Policy Guide #555.425."
Source: Chapter 20: Metal Inclusion (A Physical Hazard)
http://www.cfsan.fda.gov/~comm/haccp4t.html
The table of contents for the Hazards Guide is at:
http://www.cfsan.fda.gov/~comm/haccp4.html
Some companies may have operating limits that are more stringent than the
regulatory action level or critical limits in their HACCP plan.
My original question focuses on comments regarding the use of hand-held
metal detectors. One person wrote to me and mentioned that you need to
verify that they will work and that a lot of human error is involved. Are
there any other thoughts on hand-helds?
Pamela Tom
University of California
Sea Grant Extension Program
On Thu, 16 Jun 2005, Marcelo Hidalgo wrote:
> He all
>
> About your question, the metal detector is used in all
> factory in Ecuador, Colombia y Peru in precooked Tuna
> loims, it is very important to assure that your
> product is free of metal littlepieces ( 0.001mm)
>
> Is a requiare of FDA, in if you want to export for
> there (USA), you need it. In other hand, with this you
> save a lot claims for metal pieces.
>
> Could you review the Seafood and Fisheries Guide in
> the metal detector part.
>
> Marcelo Hidalgo
> Quality Assurance Inspector
> TRIMARINE-SOUTH AMERICA
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