We do have metal in our facility and are using metal detectors. However we are trying to avoid making metal detection a CCP. What supporting information would I need to justify the metal detection process as a prerequisite program not a CCP?
The Codex guidelines define a critical control point (CCP) as "a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level"."Essential" is the key word here. Let's say your
metal detector is calibrated to detect and reject a 4mm stainless test wand but will not reject a 3mm stainless test wand.
Is a 3mm piece of stainless steel a food safety hazard? Perhaps. In that case the
metal detector is not "essential" to prevent or eliminate a food safety hazard. Therefore it is not a
CCP.
Science is also key here. Will the
metal detector reduce a food safety hazard to "an acceptable level"?
HACCP is supposed to be "scientific and systematic". I have not been able to find any scientific study that says ingesting a 3mm piece of stainless steel is either "safe" or "unsafe". That makes setting a Critical Limit for the
metal detector rather difficult.
Also, a
metal detector is probably not going to reject a product that is contaminated with glass, brittle plastic, etc., Once again the
metal detector is not "essential" to prevent or eliminate a food safety hazard".
If a hazard has been identified at a step where control is necessary for safety/and if no control measure exists at that step or at any other, then the product or process should be modified at that step, or at an earlier or later stage, to include a control measure. If you have documentation that there have been instances of
metal contamination in your product, then the
metal detector should indeed be a Control Point. I just don't think, based on the above, that it's "Critical".
AFAIK, the distinction between a Control Point and a Critical Point is purely legal. If you say your
metal detector will "
prevent or eliminate a food safety hazard or reduce it to an acceptable level", and someone is injured by a 3mm piece of stainless steel, you open yourself up legally.
All that being said, in the baking industry here in the USA, metal detection as a
CCP is pretty much the industry standard.
Marshall