data in a graphical format that allows for
rapid and easy interpretation of negative
trends. Such an analysis may lead to the
modification of current PRPs, especially
since actions that raise total microbial
counts may contribute to increases in
pathogens. Once this is done, actions
can be taken to reduce both aerobic
plate count levels as well as minimize
the risk of producing potentially unsafe
products.
Receiving: Although many food safety
experts recommend against it, there are
processors who have identified receiving
as a CCP. The CCP mandates that a certificate of analysis (COA) be received for
each lot that is delivered. Receiving procedures must describe how the products
are to be received and how the COA results are to be reviewed and interpreted.
This is necessary to ensure that the val-
ues reported in the COA are within es-
tablished specifications and critical lim-
its. If the COA indicates that the lot in
question does not meet specifications,
the lot must be rejected since, by defini-
tion of a CCP, a product that is in
violation of a critical limit must be con-
sidered a potentially hazardous product.
If the COA is not received with the
load, the processor has two options: re-
ject the load or accept it provisionally
and place it on hold pending receipt and
analysis of the COA. In addition to a re-
view of the COA upon receipt of the
load, the plant must also establish a
procedure to verify that the process of
monitoring the COAs is being done ac-
cording to the documented receiving
procedure. This verification activity must
be done on a regular schedule. If an in-
gredient is new or its hazard potential is
Table 3: Example of a Food Safety Management System Verification Plan
Purpose
• Ensure that the
scheduling activities
take place and
are effective
• Initially validate • Ensure that
HACCP plan the validation
requirements were
properly carried out
and that the HACCP
plan will meet food
safety objectives
• Review corrective • Ensure that corrective • Review corrective
action records actions were properly action reports and
completed and conduct an audit of
effective corrective action
activities
Activity
• Schedule
verification activities
Method
• Review past
verification
scheduling
activities
• Review the
HACCP plan and
all supporting
documents,
including the
validation study(s)
Frequency
• Yearly or upon
HACCP system
change
Responsibility
• Food safety team
leader
• Prior to and during • Corporate experts
initial implementation
of plan
• Monthly
• Food safety team
leader
Validation of Metal Detection
Most metal detectors can be described as a tunnel with
a conveyor. Validation data should ensure that the equipment can detect metal of the appropriate size at different
locations on the belt, and at different locations in or around
the package. For example, if a 50-lb. sack of flour is to be
tested, the system could be validated by testing the standards at the leading edge, the tailing edge, on top of and
under the bag.
This needs to be done for each product type. The validation protocol might
even require that the standards be inserted into the bag at different locations.
Multiple tests—a minimum of 10—should be done at each location. The people
doing the validation study must also confirm that the settings remain the same
throughout the test. The result should be the determination of where to place the
test wands during calibration checks in the course of normal production. The location needs to be the spot where the magnetometer receives the weakest signal. Isn’t that a lot of work? Yes, but a rigorous test protocol such as this will
provide confidence that the system works properly.
Used with permission of Eriez,
Erie, PA
high, verification activities should be
conducted monthly or more frequently.
Metal detection: In this day and age,
most food processors utilize metal detectors, unless the package is metallized.
How many HACCP teams have taken
the time to validate that the detection
system really works? The equipment
manufacturer’s representatives will set up
the system and program it, but it is the
processor’s responsibility to validate the
metal detection equipment in the plant
using its own product (Sidebar 2, below).
In addition, the metal detector must
be properly verified to ensure its effectiveness. Most plants do verification
checks at the start of a production lot
and periodically throughout the production run. This entails passing the standards through the detector and
confirming that the metal detector recognizes each standard on the first pass. If
the detector does not recognize the standard on the first pass, corrective actions
need to be taken to first place “on hold”
all product that was scanned since the
previous good calibration check, and
then take appropriate actions to bring
the metal detector into specification. All
product placed on hold must be re-screened through a properly operating
metal detector. This can be done either
on-line or off-line.
Other problems start when different
products are run through a single metal
detector on the same day. Many times, a
calibration check is done when a new
product run is begun, and adjustments
are made to ensure the proper sensitivity.
However, is there a verification proce-
