7 replies to this topic

[Liliana Moreno]

Good Morning, 

Our Factory has as a raw material,different caned products, we normally have devices that open those tins, then we are able to use the product in our process. 

In more than 15 year of operation, we have never had metal contamination in that regards. Our production and packaging process is mostly manual and I am concern about Metal detector because we don't use that, The company already has HACCP since 2014 and it wasn't consider as a hazard. 

This is a small size family owned company we are on the way to adapt our processes to BRC standard. 

 

I would like to know your thoughts about it. 

1. Do we have to consider the metal detector? if yes,

2. Do you know about low cost devices that you can recommend? 

3. A risk assessment based on our history of non-metal issues could be accepted? 

 

As Always I really appreciate your contribution

 

Liliana Moreno. 

Australia. 

 

[pHruit]

BRC is perhaps a particularly challenging choice for this type of question, as the approach of the standard is effectively that you should have metal detection unless you can show that it doesn't improve protection of the final product, and indeed it notes that it would normally only be appropriate if an alternative and more effective system is available.

You can get a free copy of the standard here if you don't yet have one - have a a look at clause 4.10.3.1

[Charles.C]

BRC is perhaps a particularly challenging choice for this type of question, as the approach of the standard is effectively that you should have metal detection unless you can show that it doesn't improve protection of the final product, and indeed it notes that it would normally only be appropriate if an alternative and more effective system is available.

You can get a free copy of the standard here if you don't yet have one - have a a look at clause 4.10.3.1

Hi pHruit,

 

^^^ Previous posts suggest OP is currently using BRC Standard.

 

Interp.Guidelines are certainly recommended.

 

IIRC there are a (very) few instances reported here where BRC did accept non-use of a  MD.

[FSQA MKE]

You can develop a document with a risk assessment & state something along the lines of "there have been no incidences of metal contamination over 15 years". Past records of metal detection and lack of metal contamination would be required.

Notice the clause states there:

1)"shall have metal detection unless a risk assessment demonstrates..." and

2) that "absence of metal detection would normally be based on...."

Key words here are "unless" and "normally".

Just an FYI: An auditor can consider the risk assessment invalid and not suitable, but you'd still meet the requirement and could argue with the certification body and appeal the non-conformity.

See clause below:

 

4.10.3.1

Metal detection equipment shall be in place unless risk assessment demonstrates that this does not improve the protection of final products from metal contamination. Where metal detectors are not used justification shall be documented. The absence of metal detection would only normally be based on the use of an alternative, more effective method of protection (e.g. use of X-ray, fine sieves or filtration of products).

[SQFconsultant]

You would need to combine a solid risk assessment and alternate method such as sieving, filters, etc.

 

There are all sorts of metal detectors available at all sorts of prices - the best solution would be to locate a nearby provider (such as Fortress, Safeline, etc.) and customize the application.

 

X-Ray can be alternate to metal detection as well and I find in travels where companies deal with opening cans/tins they are 90% X-ray as compared to MD.

[kettlecorn]

In my experience, even in a low-risk environment, any metal to metal contact should be considered a hazard that requires metal detection. Even if, after 15 years, you haven't had an incident with metal in the product, the fact you have a device opening canned raw material tells me that you need a metal detector, because it's still a risk. I have seen parts crack or fail on machines that have worked well for decades. Metal shards were found that had fallen into product. 

 

I am no expert on BRC, but basic HACCP should identify this as a hazard. In my experience, metal detectors are cheaper than x-ray. I do sympathize with the fact that you're working in a small, family-owned business, but in this case I think the liability offsets the cost, especially if you're trying to reach the BRC standard. 

[Charles.C]

Good Morning, 

Our Factory has as a raw material,different caned products, we normally have devices that open those tins, then we are able to use the product in our process. 

In more than 15 year of operation, we have never had metal contamination in that regards. Our production and packaging process is mostly manual and I am concern about Metal detector because we don't use that, The company already has HACCP since 2014 and it wasn't consider as a hazard. 

This is a small size family owned company we are on the way to adapt our processes to BRC standard. 

 

I would like to know your thoughts about it. 

1. Do we have to consider the metal detector? if yes,

2. Do you know about low cost devices that you can recommend? 

3. A risk assessment based on our history of non-metal issues could be accepted? 

 

As Always I really appreciate your contribution

 

Liliana Moreno. 

Australia. 

JFI, Note that BRC provide a decision tree to "assist" in determining the necessity or otherwise of a metal detector.

[kingstudruler1]

I was going to point out the BRC decision tree that Charles mentioned. I think it would be hard to say you don't need metal
detection based of the decision tree.