Necessity for Metal Detectors in SFCR
Good day all,
I am involved in a start-up company here in Canada that deals with beverages and have now been faced with a predicament that I would like to share and hopefully get some advice on.
If I am getting straight to the point, we have orders to be filled within the next 30 days and are still commissioning our production lines. Presuming this commissioning and trial period go well and we are able to meet the production number for the order, we do not yet have a metal detector installed. There is a magnet, but with the quotes and lead times for food grade metal detectors that I have been provided, there is a risk that the product we are making will not go through a food grade metal detector.
It was proposed that we use a temporary wand detector, but this does not sit well with me, as I am not sure what validity this would hold with the product we will be providing. From reading the SFCR regulations, I am confident that the magnet will 'prevent, eliminate or reduce', but I am unable, at this time to be sure. These are a ready to eat product, so I am not 100% confident in my product.
Will the lack of a metal detector result in a fail for SFCR Licensing?
My apologies if this question is 'silly', this is my first time creating the entirety of a food safety system for a company.
Thank-you for any and all advice you can provide.
Regards,
Gareth
Let me ask a couple more questions so I'm sure i understand
A) you have NOT yet received your SFCR license?
B) you've installed a magnet as part of final inspections? but no MD as yet
C) you have orders you need to meet on equipment not yet commissioned? Are these inter or intra province?
Your license does not hinge on a MD, however, if your food safety plan says you should have one and you do not, then you will be in deviation of your own process right out of the gate, and you 'd need to VALIDATE that the magnet is capable of reducing the risks to an acceptable level. BTW, you would still need to validate a MD AND this validation should be done PRIOR to running product
... I am confident that the magnet will 'prevent, eliminate or reduce', but I am unable, at this time to be sure. These are a ready to eat product, so I am not 100% confident in my product.
Will the lack of a metal detector result in a fail for SFCR Licensing?
...
Nothing in the supply chain or your processing uses aluminum, copper alloy (brass, bronze), or stainless steel parts? That seems unlikely. I'm not familiar with the capacity of these magnets to capture stainless from liquid -- it seems like there would be significant flow rate limitations.
It is unlikely that a handheld metal detection device is going to be approved by the manufacturer for that kind of service, which leaves the validation up to you -- but it sounds like you don't have the time to do the study.
You mention this being a beverage product, what are the finished good containers (plastic, glass, metal)?
Scampi
Thank-you for your prompt reply. Please see answers to your questions below.
a) We do not have our SFCR license as of yet. We have a process authority coming on site that will be helping with our licensing in the near future.
b) Yes, a magnet has been installed. Our production line resembles that of a dairy production line with a UHT, homogenizer and the magnet that I had mentioned.
© Correct. We have orders for our product to be fulfilled, but our production lines have not been finalized or completely commissioned. The product will be sold intra-provincial initially but extend to inter after the initial order is fulfilled.
I have a question about the validation of a MD if we choose to get one. If we proceed, initially, with a plan that does not include a MD, we will have to adjust said plan, if and when we do install, commission and validate a MD(?).
Can a magnet pull test be performed as part of a method for validating the magnet that we have installed, among other steps?
Thank-you again, for the prompt reply.
Nothing in the supply chain or your processing uses aluminum, copper alloy (brass, bronze), or stainless steel parts? That seems unlikely. I'm not familiar with the capacity of these magnets to capture stainless from liquid -- it seems like there would be significant flow rate limitations.
It is unlikely that a handheld metal detection device is going to be approved by the manufacturer for that kind of service, which leaves the validation up to you -- but it sounds like you don't have the time to do the study.
You mention this being a beverage product, what are the finished good containers (plastic, glass, metal)?
G M,
We do have stainless steel piping in our system, essentially from start to finish. Our packaging material is a bag style made from a mixture of plastic and calcium carbonate mixture with no foil sealer.
Ideally, yes, I’d like to have a detector that is sensitive to ferrous, non-ferrous, and stainless steel, but alas, deadlines are quickly approaching. I started this role relatively recently and realized instantly that there was no such detector in place and the lead times on ordering some are upwards of 12 weeks.
Thank-you for your input thus far!
Gareth
CFIA will/should review your PCP, if your hazard analysis shows that MD is required, then you may need in it order to be granted a license. You could, however, list a magnet as the control instead and then adjust the plan once you receive and validate the MD.
I'm assuming you've got an inline magnet that will discharge product when it detects an anomaly? If so, and it can be validated for your process/product, you may not need to switch to MD as they are both controls for foreign material (assuming it will flag SS) If it will not detect SS, then you may want to think about installing additional filters with smaller screening to catch anything larger than 2mm
Your provincial body will view your PCP the same as CFIA
CFIA will/should review your PCP, if your hazard analysis shows that MD is required, then you may need in it order to be granted a license. You could, however, list a magnet as the control instead and then adjust the plan once you receive and validate the MD.
I'm assuming you've got an inline magnet that will discharge product when it detects an anomaly? If so, and it can be validated for your process/product, you may not need to switch to MD as they are both controls for foreign material (assuming it will flag SS) If it will not detect SS, then you may want to think about installing additional filters with smaller screening to catch anything larger than 2mm
Your provincial body will view your PCP the same as CFIA
Unfortunately, there is no discharge for product if and when an anomaly is detected. It is an inline magnet that's only function is to accumulate whatever material it can, to which will be inspected regularly. There are filters, to which grade I have yet to be informed.
The UHT handles the majority of our microbial issues, but there is a shearing procedure involved, which is a worrisome metal-on-metal step. The entire process is enclosed after all of the ingredients are added in, at the beginning of the process. The process flow involves heating, shearing, cooling, buffer, heating again (UHT) which is where the magnet it is, and accumulation into a 12,000L tank. The final step is packaging and boxing, which all takes place in one large instrument.
The more I converse about it, the more I am leaning towards the need for either a detector or, as you presumed, an inline discharge that is triggered by anomalies.
The single best advice for your situation, is to have vendors come to your facility to see the process, and explain exactly what your concerns are and then they can offer what they believe is the best tool for your process
There are inline MDs that will automatically discharge as well For the right $$$$$ you can have whatever you want
Scampi
Thank-you for your prompt reply. Please see answers to your questions below.
a) We do not have our SFCR license as of yet. We have a process authority coming on site that will be helping with our licensing in the near future.
b) Yes, a magnet has been installed. Our production line resembles that of a dairy production line with a UHT, homogenizer and the magnet that I had mentioned.
© Correct. We have orders for our product to be fulfilled, but our production lines have not been finalized or completely commissioned. The product will be sold intra-provincial initially but extend to inter after the initial order is fulfilled.
I have a question about the validation of a MD if we choose to get one. If we proceed, initially, with a plan that does not include a MD, we will have to adjust said plan, if and when we do install, commission and validate a MD(?).
Can a magnet pull test be performed as part of a method for validating the magnet that we have installed, among other steps?
Thank-you again, for the prompt reply.
Hi Gareth,
Validation of magnets has been discussed at some length in a few previous Posts here.
The conclusion was that it can be "complicated" depending on the specific situation. "Pulling" may/may not be a viable Validation Procedure.
Shawpak Systems provides product inspection equipment including metal detectors. They may have in stock units as well as quick ship systems available.
Consider reaching out to them for assistance.