A foreign material control program is the written way a food maker keeps things that aren't food out of food: metal, glass, stones, hard plastic, wood, gloves, jewelry. It has four parts. A list of sources: every place a foreign material could get in, from the field debris in a raw ingredient to the bolt left after a repair. A score for each, likelihood times severity, so the dangerous ones get the strongest controls. Controls: prevent it getting in, such as no jewelry and tools counted out and back, or find and remove it, such as a sorting belt, a sifter, a magnet or a metal detector. And checks and records, so you can show the controls work. The federal food rule asks for adequate measures against metal or other extraneous material, and for facilities with preventive controls, physical hazards like stones, glass and metal fragments belong in the hazard analysis. FDA's line for action: a hard or sharp object 7 to 25 mm long in ready-to-eat food is adulterated, and smaller when the food is meant for infants or other special-risk groups. In the example below, a nut butter maker scores nine sources after a customer complaint. Below are the sources, the rules, the example, and a free register.
The short version
- A foreign material program keeps metal, glass, stones, plastic and the rest out of food.
- List every source: ingredients, equipment wear, repairs, packaging, people.
- Score each: likelihood times severity, 1 to 5 each.
- Prevent first; then find and remove: sorting, sifting, magnets, metal detection.
- Check that each control works, and keep the record.
- FDA treats hard or sharp pieces 7 to 25 mm in ready-to-eat food as adulterated.
- TaroStack keeps each run as a lot, so a complaint leads to the run and the stores. More below.
The sources
| Source | Examples | Typical controls |
|---|---|---|
| Raw ingredients | Stones, shell, twigs, metal from the field or the mill | Supplier specification, sorting, sifting, magnets |
| Equipment wear | Grinder burrs, blades, screens, belts | Inspection on a schedule, metal detection |
| Repairs | Bolts, nuts, wire, tools | Tools counted in and out, line cleared and checked after |
| Packaging | Glass jars, brittle lids, staples | Breakage procedure, inspection at receiving |
| Utensils | Scoops, buckets, brushes | Colored and checked before use, no wood |
| People | Jewelry, pens, hairpins, bandages, gloves | No jewelry, detectable gloves and bandages |
| The building | Light covers, flaking paint, pallet wood | Covered lights, maintenance, pallets kept off the line |
The rules
| Rule | Where |
|---|---|
| Metal and extraneous material | Adequate measures to protect against its inclusion in food (21 CFR 117.80(c)(8)) |
| People | Unsecured jewelry and other objects that might fall into food removed (117.10(b)(4)) |
| Hazard analysis | Physical hazards, such as stones, glass and metal fragments, evaluated (117.130(b)(1)(iii)) |
| FDA's action line | Hard or sharp objects 7 to 25 mm long in ready-to-eat food, or food needing only minimal preparation, adulterated (CPG Sec. 555.425) |
| Smaller pieces | Under 7 mm when infants, the elderly or other special-risk groups are among the intended consumers (CPG 555.425) |
Where a metal detector becomes a critical control point is in peanut butter HACCP plan, and the plan around it in what is a food safety plan. This is general information, not legal advice.
An example: a Little Rock nut butter maker
Red Oak Nut Butters, the made-up nut butter maker in Little Rock, Arkansas, I use in these examples, already runs every jar through a metal detector. In August a customer found a piece of peanut shell in a jar, and the owner scored every source again:
| Foreign material | Likelihood | Severity | Score | Rating | Control |
|---|---|---|---|---|---|
| Stones and shell in raw peanuts | 4 | 4 | 16 | High | Supplier spec; sorting belt after roasting, rejects looked at every lot |
| Metal from grinder burrs | 3 | 4 | 12 | High | Metal detector, test pieces hourly; burrs inspected weekly |
| Glass from a broken jar | 2 | 5 | 10 | Medium | Breakage procedure: stop, clear, discard open jars nearby |
| Bolts, nuts, tools from repairs | 2 | 4 | 8 | Medium | Tools counted in and out; line cleared after a repair |
| Hard plastic: scoop, bucket, lid | 2 | 3 | 6 | Medium | Colored utensils, checked before use |
| Gloves and bandages | 3 | 2 | 6 | Medium | Blue detectable gloves and bandages |
| Jewelry, pens, hairpins | 2 | 3 | 6 | Medium | No jewelry; nothing in pockets above the waist |
| Wood splinters from pallets | 2 | 2 | 4 | Low | Kept off the line |
| String from sacks | 3 | 1 | 3 | Low | Cut at the seam, string to the bin |
Shell isn't metal, so the detector can't find it; the sorting belt can. Before the complaint, the rejects on the belt were looked at monthly; now every lot's rejects are looked at and noted on the receiving log, and a supplier lot with more shell than usual goes back. The complaint itself is in the customer complaint log, and what to do with the jars while it's looked into in hold and release procedure.
Get the template
Download the foreign material risk register. One sheet: each foreign material, where and how it gets in, likelihood and severity from 1 to 5, the control, the check and how often, and the record; the score and rating fill in, and a high or medium risk with no control shows in red. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
A register says the controls exist. When a customer finds shell in a jar, the questions are which run it came from, which supplier lot of peanuts went into it, and which stores got the rest of that run.
How TaroStack does it
TaroStack makes each run a lot that records the supplier lots it used, so a complaint leads to the run, the peanuts and the stores.
Supplier lots into batches. Each delivery of peanuts is received with the supplier's lot, and each batch records the lots it used, so a jar's lot leads back to the peanuts.
Your own fields. Receiving can carry fields of your own, such as the sort rejects for the lot, and batch records can carry the metal detector checks for the run.
Holds and recalls. Jars from a doubtful run can be put on hold, kept out of what's available to sell, and if they have to come back, one recall report shows every store that got them.
| The job | Binder | In TaroStack |
|---|---|---|
| Which run a jar came from | Read the lid | The jar's lot |
| Which peanuts went into it | Search the receiving sheets | Supplier lots on the batch |
| Sort rejects for a lot | A clipboard | A field on the receipt |
| Which stores got the run | Invoices | One recall report |
Receiving, lots, batches, your own fields, holds and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.