Managing Foreign Body Contamination in Certification Audits

Foreign bodies in food not only pose a health risk to consumers, but can also have far reaching consequences for food producers and can permanently damage a brand. One way to detect any weak points in the process, as early as possible, is through regular certification audits.

We spoke to Oliver Eck, Head of Food Agriculture Western Europe at TÜV Nord, about his views on managing foreign body measures through certification audits, the steps to successful audits and what the future holds for foreign body contamination.

Oliver Eck, Head of Food Agriculture Western Europe at TÜV Nord

Thank you Mr. Eck, could you briefly introduce yourself and also describe your relationship to the topic of foreign body management?

I am Head of Food and Agriculture Western Europe at TÜV Nord and Managing Director of TÜV Nord Austria.  I am also Lead Auditor for the main food safety standards e.g. HACCP, FSSC 22000 and IFS. My industry experience of foreign body management started with artisan butcher training many years ago.

In your opinion, what are the most important factors in foreign body management?

The most important goal is to prevent foreign objects from getting into the product in the first place. There are many ways this contamination can occur. Foreign bodies can enter the product via the raw materials, the production process or through defects in the building or the environment. It is therefore important to establish good raw material management, effective incoming goods inspections and set up appropriate hygiene protocols to reduce the risk of contamination.

If contamination does occur, the question is how to remove the foreign body from the product and which method is best. Is a metal detection or x-ray system the right choice, a sieve, a magnet or perhaps a mix of all of these? It is very important for the company itself to define that. Of course, it also depends a lot on what the potential hazards are in the first place.  Many companies think that they need a metal detector otherwise they won't get certification. That is not the case. It always depends on the hazard analysis carried out. If there is a risk of a piece of metal getting into the product, then there is a need to install something that helps detect the foreign body. 

Another factor to consider is the risk to consumer health, should a piece of metal get into the final product. Consider how likely it is that contamination will occur and how big the impact would be on the consumer. If there isn't a risk, then there's no need for a metal detection solution.

To summarize, it really depends on how the company's hazard analysis is structured and what risks are highlighted in the hazard analysis. How the risks are dealt with varies from company to company.

Mr. Eck, you contributed to the IFS guidelines on foreign body management. What role do these measures now play for certification audits?

The measures to prevent foreign body contamination are enormously important in an audit. Foreign body contamination is one of the more common complaints voiced by consumers and can lead to adverse health effects. For that reason, this is the main focus of the certification audit.

Every company installs and implements its own HACCP system and therefore its own HACCP plan. The auditor first checks what risks the company has identified, what the internal guidelines are and how they are implemented.

The auditor also has the standard industry processes in mind. Against the background of the technology used to prevent contamination, an assessment is made of the extent to which the measures implemented are really suitable for producing safe, legal products that meet the requirements in terms of quality.

From your experience as an auditor, what are the biggest challenges for food producers in foreign body management?

Once the company has worked out the right methodology, it is very important for them to complete the entire process. They should evaluate, how to validate the equipment, what is needed to create, install or carry out the validation to have an effective process.

Once the commissioning or the initial validation has been carried out, there needs to be effective employee training to create a food safety culture within the company so everyone is aware of what is at stake. This has to be done in such a way that every employee is aware how a functioning or a non-functioning product inspection device has an impact on consumer health.

In order to maintain the newly created food safety culture, the training must be continuously followed and practiced. For example, the auditor will check whether the metal detectors are being tested. If this is done, then not only should the metal detector sound an alarm, but the reject device must also function. As an auditor, you notice relatively quickly how well the food safety culture is established in a company and how contamination issues are dealt with.

A thorough hazard analysis is the key to preparing an effective HACCP plan. If the hazard analysis is not done correctly and the hazards warranting control within the HACCP system are not identified, the plan will not be effective regardless of how well it is followed. The analysis provides a basis for determining Critical Control Points (CCPs). CCPs are located at any step where hazards can be either prevented, eliminated, or reduced to acceptable levels. Examples of CCPs may include: thermal processing, chilling, testing ingredients for chemical residues, product formulation control, and testing product for metal contaminants.

How is foreign body management implemented internationally? Is it the same everywhere or are there different approaches in different countries?

In principle, this should be handled in the same way, everywhere. The requirements for foreign body detection are the same. A glass splinter in a chocolate bar in Germany is no less dangerous than a glass splinter in Asia or Africa. 

What is TÜV Nord doing to raise awareness about foreign body management?

The auditor from TÜV NORD naturally examines the topic in the audit and, if necessary, enters into discussion with the individual companies. But we cannot provide advice or training, because we are not allowed to do that as a certification company. However, TÜV Nord does have the TÜV Nord Academy, where you can request training through online and in-house seminars. This includes foreign body detection seminars.

Has the recent pandemic had an impact on foreign body detection?

In my view, the Corona pandemic has had no impact on foreign body detection or management. This is because foreign bodies are not less dangerous due to the pandemic. However, there have been challenges with how foreign body management is carried out across companies and how we are able to audit them when social distancing rules apply. There have been companies that unfortunately found themselves in the situation where entire shifts were quarantined or key personnel who check the metal detectors were absent. This has sometimes been difficult to ensure that sufficient competence is available for the audit testing.

How do you see the future of foreign body detection? How will the standard requirements or audit practices develop?

In the future, audits will most likely focus more on system security and documentation, for example in metal detectors, the need for data that can be obtained remotely and used as a basis for verification or process optimization.

I find it interesting that a detected metal chip in a product could be automatically analyzed with regard to the type of metal and then matched with an existing tool.

In this way, the company can promptly determine the source of the contamination and also initiate preventive measures or training measures. I imagine we are only at the beginning of the possibilities here.

Thanks for this interview, Mr. Eck. 

For more information on this topic, visit the TÜV Nord website or get in contact with foodcert@tuev-nord.de.