PAS 220 says you can skip any requisite, but it should be justified by a hazard assessment.
"Food manufacturing operations are diverse in nature and not all of the requirements specified in this PAS apply to an individual establishment or process.
Sorry for the late response. My participation in this forum is severely hampered by the lack of available time.
I agree and it is only logical to opine that suggested
specifications under PAS220 or ISO22002 cannot be fully applied as it depends on the nature of the processes / characteristics of the product including other process & product parameters as these are applied to an individual establishment.
As we perform hazard analysis base on data obtained from our preliminary studies (layout design, process flow, PD, etc...), the suitability and relevancy of PRPs were/are duly considered. In this instance, we would take into account the specifications outlined under PAS220 or ISO22002 but as always purely as a point of reference.
To satisfy food auditors that specifications listed under ISO22002 had been considered since the release on 15th Dec. 2009, we have been conducting PRP Review-Audits for our clients base on such considerations as listed in the ISO/TS to determine relevancy/currency of existing PRPs and attach with justifications for any "exclusions", if any. This was done on a matrix format.
In summary, we are on the same page.