I agree with Greg. In particular I would like to underline that in small not
highly mechanized plants to check daily (or after each shift) knives, saw
blades, staples (if any around; e.g. in carton boxes of raw material) or any
other similar elements and instruct people to alert on broken knives, loose
rivets and nuts on surfaces and equipment, etc; could suffice to control
metallic inclusions.
During our workshops on HACCP Audit one of the practical works in plant, is
to check floors, equipments, work surfaces for metallic (and non metallic)
pieces (pieces of wire, nuts, bolts, rivets, concrete, etc). We put them in a
plastic bag and take note of the place where it has been found. We also check
for knives and saw blades, to put side by side knives of the same type is
very useful to compare size and changes in the geometry of the blade (you can
sharp and modify the blade as you wish). This is a very nice exercise to
train HACCP auditors because:
(i) The more mechanized the plant the more possible the inclusion of metallic
pieces.
(ii) If a metallic piece can jump from the floor inside of a package imagine
a bacteria.
(iii) What about the non-ferrous materials?
(v) Are the pieces found old or new (e.g. rusting)? What about the cleaning
program of the plant?
(iv) Is it possible to know from where the pieces came? What about
maintenance?
(v) What about the quality of our knives, saw blades? Are the knives utilized
the proper ones?
(v) What we have to do to reduce the risk(s)?
We can divide hazards for study and regulations, but a plant is a unity, like
a live body, and when there are problems in some area, surely there are
problems in other areas too. Like in the case of a live body, there are
illnesses and symptoms; foreign pieces (metallic and non metallic) are a
hazard and at the same time a symptom (of other possible hazards).
In our case this exercise is part of a mock (partial) internal HACCP Audit to
train HACCP auditors that we have carried out in several developing
countries, all around the world. Usually we have access to the plants because
companies have accepted voluntarily we train HACCP auditors (their own
internal HACCP auditors, those of other companies and regulatory HACCP
auditors) in real situations. Not always the people that have offered their
plants freely for the mock exercise are initially happy and they sweat with
each not compliance we found, but as an owner of a plant told me, "this has
saved me thousands of dollars".
Hector M. Lupin
Senior Fishery Industry Officer (Quality Assurance)
Fish Utilization and Marketing Service (FIIU)
Fishery Industries Division (FI)
Fisheries Department, FAO of the UN, Room F 606
Viale delle Terme di Caracolla
00100 Rome, Italy
Tel + 39 06 570 56459
Fax + 39 06 570 55188
E-mail: hector.lupin@fao.org
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
Of GregoryScher@ln.amedd.army.mil
Sent: 16 June 2005 21:11
To: Pamela Tom
Cc: Marcelo Hidalgo; owner-seafood@ucdavis.edu; Seafood HACCP Discussion List
Subject: Re: Metal detector
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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