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#1 Dux

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Posted 23 March 2011 - 08:52 AM

What is OPRP?

3.9 operational PRP
PRP identified by the hazard analysis...................

From the concept, essencially OPRP is belong to one of elements of PRP before hazard analysis.

Whait is PRP?

3.8 PRP
basic conditions and activities that are necessary..............

that means elements of PRP are no relationshop with designated food product.

however, why in Clause 7.4.4, say "the selection and categoriztion shall be carried out using a logical approach............."?

Could anyone help me? Thanks!


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#2 Modarres

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Posted 23 March 2011 - 01:12 PM

What is OPRP?

3.9 operational PRP
PRP identified by the hazard analysis...................

From the concept, essencially OPRP is belong to one of elements of PRP before hazard analysis.

Whait is PRP?

3.8 PRP
basic conditions and activities that are necessary..............

that means elements of PRP are no relationshop with designated food product.

however, why in Clause 7.4.4, say "the selection and categoriztion shall be carried out using a logical approach............."?

Could anyone help me? Thanks!


Hi!

We have 3 types control measures in 22000:
1. PRPs, that run generally and are public for making hygiene environment. (clause 7.2)
2. OPRPs, including some selected PRPs that are essential for FS based on hazard assessment and should be monitored. (clauses 7.4.4 and 7.5)
3. CCPs, which are critical, if not run may FS hazards come into, based on hazard assessment and should be monitored. (clauses 7.4.4 and 7.6)

Methodology:
1. Determination PRPs based on legal requirements... (7.2)
2. Do hazard analysis and determine control measure combination (7.3,7.4.1-3)
3. Do control measure combination validation for assess if they are effective or not (8.2)
4. Assess and categorize the control measures to two sections (7.4.4)
5. Install OPRPs (7.5)
6. Install HACCP Plan (7.6)

See attachment for example...

:king:

Attached Files


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#3 Charles.C

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Posted 24 March 2011 - 11:53 AM

Dear Dux,

PRP’s typically system wide and as per the definition.
OPRP’s may or may not be system wide and as per the definition and/or para.7.4.4 (a-g)
CCPs normally specific and as per the definition and para 7.4.4 (a-g)
(all the above probably hv readily quotable exceptions, this is not a black/white subject :rolleyes: )

Typical PRPs are listed in PAS220 or FSSC 22000 but you can have more if you wish (ISO love documentation).
OPRP often = near CCP as per 7.4.4 (a-g) or perhaps an upgraded PRP.
ISO CCP = Codex CCP unless not conforming to para 7.4.4 (a-g) (when it would become an OPRP)

Slightly confused, join the club! But don’t worry too much since ISO 22004 says the choice between CCP and OPRP does not really matter anyway (as long as you hv a consistent/logical/validatable decision procedure).

@Modarres I admire the overall intention of yr plan but some of the content is rather debatable IMO. A few examples -

Q2: Is the Control Measure feasible for monitoring? Possible answer : No
IMHO, this answer causes the proposed Control Measure to be totally infeasible. End of evaluation.

Q3: Is the Control Measure's place within the system relative to other control measures?
Sorry but, as stated, the question and possible answers given have limited meaning to me. Maybe translation problem.

Q6: Is the control measure specifically established and applied to eliminate or significantly reduce the level of hazard(s)?
Define significantly.(maybe ISO should answer, the words are theirs :smile: )

Q7: Have the Control Measure synergistic effects?
Answers both agreeing and totally disagreeing with any possible importance can be found depending on the source. Not a criticism, just an observation. Perhaps the option should be equally Y or N ?

However, as suggested by ISO 22004, attempts to be too analytical regarding queries (a-g) are probably a waste of time for the user / from most auditor's viewpoints?. :smile:

Basically i think ISO simply tried to be a bit too clever. :smile:

Rgds / Charles.C


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#4 Dux

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Posted 25 March 2011 - 12:41 AM

Thanks!

I know the clauses in ISO22k.

But my question is why the DEFINATION of "OPRP" in Clause 3.9 say 'OPRP' is 'PRP' identified by the hazards analysis................

As we all know, "3. Terms and definations" is always FOUNDATION of an ISO stardard, and nothing can change the defination of a term.

However, in context in Clause 7 of ISO22k, also some explanations in ISO22004, the defination of "OPRP" was extended NOTtotally MATCHING the original defination.

I don't think it is a clever of ISO, but a miss.




Hi!

We have 3 types control measures in 22000:
1. PRPs, that run generally and are public for making hygiene environment. (clause 7.2)
2. OPRPs, including some selected PRPs that are essential for FS based on hazard assessment and should be monitored. (clauses 7.4.4 and 7.5)
3. CCPs, which are critical, if not run may FS hazards come into, based on hazard assessment and should be monitored. (clauses 7.4.4 and 7.6)

Methodology:
1. Determination PRPs based on legal requirements... (7.2)
2. Do hazard analysis and determine control measure combination (7.3,7.4.1-3)
3. Do control measure combination validation for assess if they are effective or not (8.2)
4. Assess and categorize the control measures to two sections (7.4.4)
5. Install OPRPs (7.5)
6. Install HACCP Plan (7.6)

See attachment for example...

:king:

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#5 Charles.C

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Posted 25 March 2011 - 02:07 AM

Dear Dux,

ISO 22004 operationally supercedes ISO 22000.

It was a convenient way for ISO to attempt to clarify (nullify?) certain "confusions" in ISO 22000 without changing the definitions.

(Unlike EC Directives, I don't think ISO is too enthusiastic about issuing official corrigenda, especially perhaps after charging for the original.)

IMO, ISO 22004 contains some excellent informative material but also attempts to quietly acknowledge / insert some major internal re-thinks on the OPRP / CCP definitions / interpretations of ISO 22000. Unfortunately, as per yr observations, sole use of ISO 22000 tends to perpetuate the confusion. I suspect that auditors hv long ago made their own interpretations of the (acceptable) requirements. How much difference (ie range) is found in practice i hv rarely seen discussed here ?? :smile:

Rgds / Charles.C


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#6 D-D

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Posted 01 April 2011 - 07:51 AM

Does it matter if you call something a PRP or not as long as you have the procedure in place and operating?
We are working towards BRC and bought the 'universal' manual promoted on this site. BRC barely mentions 'PRP' so I ditched that nomenclature as I edited the procedures and just put them all in one bundle (there are 38 of them now!).


Edited by D-D, 01 April 2011 - 07:52 AM.

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#7 Charles.C

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Posted 02 April 2011 - 05:02 AM

Dear D-D,

Does it matter if you call something a PRP or not as long as you have the procedure in place and operating?


Well, it rather depends on what the audit is for ? :smile:

Does yr (BRC-induced) disparagement of the PRP concept extend to GMP also ? :smile:

I think you are vaguely comparing BRC's structure to ISO 22000 ? Apples and Oranges I'm afraid. :smile:

Rgds / Charles.C
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#8 SriramB

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Posted 02 April 2011 - 09:28 AM

Thanks!

I know the clauses in ISO22k.

But my question is why the DEFINATION of "OPRP" in Clause 3.9 say 'OPRP' is 'PRP' identified by the hazards analysis................



Hi Dux, (and anyone else...)

Just wondering if you can give an example of an oPRP, which is not an " 'PRP' identified by the hazards analysis."

Will help me in defining the issue,....

Cheers,

SriramB
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#9 Charles.C

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Posted 02 April 2011 - 02:48 PM

Dear Sriram B,

PRP' identified by the hazards analysis


Not too sure what this means. :smile:

According to ISO 22004, "PRPs are not selected for the purpose of controlling specific identified hazards but for the purpose of maintaining a hygienic production, processing and/or handling environment". In practice, rightly or wrongly, this is not always quite the case i suspect. :smile:

Although in the end, the decision as to oprp/ccp is subjective thanks to 7.4.4 (a-g), one "validatable" example is the filtration step in a water treatment process (a reason being the typical inability to perform continuous monitoring).

Rgds / Charles.C
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#10 D-D

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Posted 04 April 2011 - 01:30 PM

Dear D-D,



Well, it rather depends on what the audit is for ? :smile:

Does yr (BRC-induced) disparagement of the PRP concept extend to GMP also ? :smile:

I think you are vaguely comparing BRC's structure to ISO 22000 ? Apples and Oranges I'm afraid. :smile:

Rgds / Charles.C


Well we've got HACCP at the core of course then as far as I'm concerned everything else is PRP or GMP even if it doesn't have either label on it.
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#11 Ken

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Posted 11 April 2011 - 01:56 PM

From someone who was initially confused by oPRP's wondering why ISO were trying to complicate Haccp unnecessarily, I have to say that I now think that the concept of oPRP's is logical and in practice is very useful. Reason for my change of opinion is the development and implementation of Haccp for ISO 22000. The difficulty is that there isn't a universally accepted method or decision tree for differentiating between CCP's and oPRP's - some of the examples I have seen have been too complicated.

If you take the principle that, for each hazard, you assess the significance (Likelihood x Severity) and if the hazard is not significant, there is no point putting it through a decision tree to (It is illogical to try and decide if an insignificant hazard is a CCP or not!).

Once you get that bit out of the way, you are left with the significant hazards. By definition, if the team believes them to be significant then there must be some sort of controls in place. The type of controls and frequency of monitoring will differ but there will be some control in place whether it is a PRP, oPRP or CCP.

As for differentiating between an oPRP and CCP, here is an ADAPTED CODEX DECISION TREE I have used for ISO 22000 and have seen developed quite independently by a customer - not perfect, but possibly simpler and more logical than some others I have seen. I will leave it to you to decide if it is useful!

A good example of an oPRP compared to a CCP is say sieving / filtration. If you can imagine a factory which has filtration at the beginning, middle and then end of a production line immediately before a filling machine. The final filtration step before filling will be the CCP as there isn't a later stage which will control physical hazards. It is this CCP which will be frequently monitored. e.g. at a frequency of every shift

In 'traditional' haccp, the first 2 filtration stages will fall out of the decision as 'Not a CCP' as there is later stage which will control the hazard. (Filtration at the filling stage)

Under ISO 22000, the first two filtration stages will both be oPRP's, BUT the level and type of monitoring will be different e.g. checked once a week by the engineers. Failure at these filtration steps will NOT be critical for the safety of the product but they still need to be monitored - it is the frequency and type of monitoring which will be different.

Attached Files


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#12 Charles.C

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Posted 11 April 2011 - 08:44 PM

Dear Ken,

Always interesting to see more input on this topic. Cheese to the mouse. :thumbup:

One (possible) fundamental objection to the attached scheme is that the decision as to CCP/OPRP only involves approx. half of the content of 7.4.4 (a-g). Opinions on whether this matters are of course a major reason for the plentiful alternative schemes. ISO 22004 and many auditors apparently think not. So perhaps unlimited, albeit validatable, subjectivity is the final (pragmatic) comment on ISO’s grand vision. (only my opinion of course :smile: ).

Rgds / Charles.C

PS In my ffox, the attachment appeared either as a very small object or a giant. Just in case other's hv same problem, I attach a, slightly, easier to zoom pdf. Hopefully other people won't need it. :smile:
Attached File  Ken\'s attachment.pdf   3.14MB   274 downloads


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#13 Ken

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Posted 12 April 2011 - 06:42 AM

Charles

Sorry I had problems uploading attachments - working on a mac so don't know if that should make a difference.

Good points about 7.4.4. a-g. - yes you do have to assess control measures using 'a logical approach' but that isn't the same as inventing a complicated decision tree which few people can understand to categorise hazards! The example given in 22004 isn't particularly helpful either as it doesn't explain the basis for the categorisation of oPRP's & CCP's.

After all we are basing all this on Codex even though ISO 22000 does complicate a few things. I like the the KISS approach and this method does it for me, has logical and hasn't been as issue with auditors.

!'m not even sure if we will get a consensus on this issue - would be helpful if those who developed the standard could provide better guidance as those nice people at BRC have done with the BRC Global Standard for Food :clap:


Edited by Ken, 12 April 2011 - 07:00 AM.

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#14 SriramB

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Posted 12 April 2011 - 09:55 AM

Charles


Good points about 7.4.4. a-g. - yes you do have to assess control measures using 'a logical approach' but that isn't the same as inventing a complicated decision tree which few people can understand to categorise hazards!



Dear Ken.

Enjoyed reading your post, I too have found oPRPs to be a welcome categorization for all the important controls which do not fit into CCPs because their impact is not assesed easily by the original codex tree.

But one other offshoot of the OPRP concept is that if a measure does not form CCP and also does merit being an OPRP (i.e. the measure is not reducing the hazard to level where other controls are effective) , then the measure becomes a waste of money/space to the organization.

When we develop the decision tree it becomes helpful if it can identify redundant controls in addition to CCP and OPRP.

Wonder if anyone has a good Dec Tree that covers all of 7.4.4

cheers,

SriramB
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#15 Claudia_QP

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Posted 15 April 2011 - 08:12 PM

a PRP is a control measure realted to GMP basically

OPRP is a control measure but related to your process. You stablish this measure because of the nature of YOUR operation. i.e a temperature control, presure, light intensity, flow speed, etc.

CCP: Normally is a OPRP that represents a hazard related to food safety, when is not done

I find it really usefull to clasify them this way.
:smile:


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#16 Charles.C

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Posted 15 April 2011 - 10:48 PM

Dear Sriram,

Various trees already exist on this forum for separating control measures (CM) associated with an OPRP/CCP. Whether they are any “good” or not is IMO rather difficult to say (ie based on what parameter(s)?) (a few published proposals do exist which I suppose could act as a validation?). I guess this uncertainty is one reason for a seemingly popular "sideways" approach whereby the standard Codex tree for CCPs is applied, failure of a CM matching is then automatically concluded to denote an OPRP entity. This yields a relatively painless process even if maybe rather divergent from the original scoped intentions of the ISO 22000 standard (eg see the 3.9 definition of OPRP, and below).

It can be argued that a literal reading of the (English) version of the 22000 standard demands consideration of all the elements within 7.4.4 (a-g). This comment IMO is validated by the words “shall” and “includes”.

However ISO 22004 (para 7.4.4) “indicates” that a narrower use of 7.4.4 (a-g) is also possible, eg “shall” > “may”. AFAIK, this document operationally supercedes ISO 22000.

ISO 22004 also indicates that the precise categorisation of control measures into OPRP or CCP is basically unimportant (!!), the key aspect is that for either case, a proposed CM must be validatable “as capable of achieving the intended level of control” (presumably as defined by ISO 22000, para 7.4.4).

I suppose the preceding paragraph is a kind of justification for the auditorial acceptability of approaches based on evaluation of as few as 4 (or less?) up to all 7 constituents of (a-g) (including some tree methods). Whether some auditors are more demanding than others, no idea (at one time I believe the answer was yes but by now I suspect a pragmatic rationalisation will hv set in ? :smile: )

Rgds / Charles.C


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#17 SriramB

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Posted 16 April 2011 - 12:14 AM

Dear Sriram,

It can be argued that a literal reading of the (English) version of the 22000 standard demands consideration of all the elements within 7.4.4 (a-g). This comment IMO is validated by the words “shall” and “includes”.

However ISO 22004 (para 7.4.4) “indicates” that a narrower use of 7.4.4 (a-g) is also possible, eg “shall” > “may”. AFAIK, this document operationally supercedes ISO 22000.

ISO 22004 also indicates that the precise categorisation of control measures into OPRP or CCP is basically unimportant (!!),

I suppose the preceding paragraph is a kind of justification for the auditorial acceptability of approaches based on evaluation of as few as 4 (or less?) up to all 7 constituents of (a-g) (including some tree methods). Whether some auditors are more demanding than others, no idea (at one time I believe the answer was yes but by now I suspect a pragmatic rationalisation will hv set in ? :smile: )

Rgds / Charles.C


Very nicely put, and I am beginning to understand why, you have, in earlier posts, indicated that the language/ tone of ISO22004 seems, to imply that ISO is trying to cope with the difficulties of transferring OPRPs , as a concept, to end users.

:off_topic:
I had to develop a Dec Tree some time back , and the fact that i havent posted it yet, shows my 'faith' in it :smile: . But, I agree that auditors are providing some latitude, to allow every FS team to document their HACCP as they see fit provided the, due diligence towards each CM is demonstrated to what 'they' determine to be an acceptable threshold.;)

Cheers,
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#18 Quah

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Posted 30 May 2011 - 03:20 PM

Would it be appropriate to equalize oPRP as CP in HACCP? Cause definition it indicate as if it is CP (control point).


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#19 Charles.C

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Posted 30 May 2011 - 08:18 PM

Would it be appropriate to equalize oPRP as CP in HACCP? Cause definition it indicate as if it is CP (control point).


Dear Quah,

You might find this thread helpful -

http://www.ifsqn.com...dpost__p__45477

Rgds / Charles.C

PS If not already done, Welcome to the forum ! :welcome:
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#20 Tony-C

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Posted 09 June 2011 - 05:19 PM

Does it matter if you call something a PRP or not as long as you have the procedure in place and operating?
We are working towards BRC and bought the 'universal' manual promoted on this site. BRC barely mentions 'PRP' so I ditched that nomenclature as I edited the procedures and just put them all in one bundle (there are 38 of them now!).


Thank you for buying one of our systems, we hope that you found it useful.

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#21 Tony-C

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Posted 09 June 2011 - 05:27 PM

Charles

Sorry I had problems uploading attachments - working on a mac so don't know if that should make a difference.

Good points about 7.4.4. a-g. - yes you do have to assess control measures using 'a logical approach' but that isn't the same as inventing a complicated decision tree which few people can understand to categorise hazards! The example given in 22004 isn't particularly helpful either as it doesn't explain the basis for the categorisation of oPRP's & CCP's.

After all we are basing all this on Codex even though ISO 22000 does complicate a few things. I like the the KISS approach and this method does it for me, has logical and hasn't been as issue with auditors.

!'m not even sure if we will get a consensus on this issue - would be helpful if those who developed the standard could provide better guidance as those nice people at BRC have done with the BRC Global Standard for Food :clap:


:thumbup:

I agree use the traditional decision tree but if you conclude that a significant hazard isn't a CCP then it should be an OPRP.

I think some people try to make to much of it.

Regards,

Tony
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#22 Charles.C

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Posted 10 June 2011 - 02:34 AM

Dear TonyC

I am totally in favour of implementing the simplest auditorially acceptable response to the 22000’s section 7.4.4.
However it also seems to me that the format of the Codex Tree(s) we are discussing is surely not in conformance with the intended concept of ISO 22000?
My conclusion is that auditors seem to hv interpreted ISO 22004 as permission to dump section 7.4.4 (a-g) and replace it with any validatable procedure which defines CCPs. The balance then defaults to OPRP as you mention.
One further pragmatic “prerequisite” to above comments seems to me to organise the initial hazard analysis so as to absolutely minimise the input to the oprp/ccp segment.

Ken’s modification of Qu3 seems directly oppposed to the Decision Tree in ISO 22004 to me but this inclusion was perhaps intended to soften the conceptual consequences referred above. Seems to be equating OPRP to a “Significant” yet ultimately “Non-significant” Control Point, whatever that means. :whistle:

Even simpler proposals to Ken’s are also apparently in use although some continue to attempt, I think, to maintain a linkage to ISO 22000. The net result is also to generate some confusion IMO, eg –

Attached File  CCP - OPRP DecisionTree.png   49.46KB   148 downloads

Rgds / Charles.C

Added - can see some similarities in above attachment to this one for petfood (previously posted in another thread)-

Attached File  iso 22000 oprp decision tree, 2010 -.png   89.53KB   128 downloads


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#23 HPG

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Posted 10 June 2011 - 02:55 AM

Dear TonyC

I am totally in favour of implementing the simplest auditorially acceptable response to the 22000’s section 7.4.4.
However it also seems to me that the format of the Codex Tree(s) we are discussing is surely not in conformance with the intended concept of ISO 22000?
My conclusion is that auditors seem to hv interpreted ISO 22004 as permission to dump section 7.4.4 (a-g) and replace it with any validatable procedure which defines CCPs. The balance then defaults to OPRP as you mention.
One further pragmatic “prerequisite” to above comments seems to me to organise the initial hazard analysis so as to absolutely minimise the input to the oprp/ccp segment.

Ken’s modification of Qu3 seems directly oppposed to the Decision Tree in ISO 22004 to me but this inclusion was perhaps intended to soften the conceptual consequences referred above. Seems to be equating OPRP to a “Significant” yet ultimately “Non-significant” Control Point, whatever that means. :whistle:

Even simpler proposals to Ken’s are also apparently in use although some continue to attempt, I think, to maintain a linkage to ISO 22000. The net result is also to generate some confusion IMO, eg –

Attached File  CCP - OPRP DecisionTree.png   49.46KB   148 downloads

Rgds / Charles.C


Dear Charles,
As I see at your attachment, can I define the first no CCP (at third question) as OPRP?
For example : Baking. For the third question (exceeding occur), if I say no, can I say that baking is an OPRP?

Btw, how can I explain to others people beside our employee (e.g. food consultant) about Baking as an OPRP? (because he said that baking "usually" a CCP)

Regards,
Hadi
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#24 Charles.C

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Posted 10 June 2011 - 06:20 AM

Dear HPG,

As I see at your attachment, can I define the first no CCP (at third question) as OPRP?

As i interpret the attachment, the answer is no.

I am assuming the hazard you refer is failure to adequately destroy any specified pathogenic bacteria during the baking process.

Assuming the detailed situation at this step is as described in the Codex Tree/Q3, IMO a NO answer implies that the hazard does not pass the screening step 7.4.3 of ISO 22000, ie it is not a CCP or an OPRP. This is also illustrated in Fig3 of ISO 22004.

If you prefer the decision tree posted by Ken, yr result will presumably be that it (the control activity) is an OPRP unless you initially determined that the hazard is not significant enough to be analysed by the Codex Tree.

Interested to hear any other opinions. :smile:

ADDED LATER - there is some further discussion on the above aspect at post#39 of this thread, see the postscript: "added(2)"

Rgds / Charles.C

PS I daresay yr food consultant prefers to not select the NO answer you are mentioning. :smile:
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Charles.C


#25 Fredi

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Posted 10 June 2011 - 07:26 AM

Dear Dux,

PRP’s typically system wide and as per the definition.
OPRP’s may or may not be system wide and as per the definition and/or para.7.4.4 (a-g)
CCPs normally specific and as per the definition and para 7.4.4 (a-g)
(all the above probably hv readily quotable exceptions, this is not a black/white subject :rolleyes: )

Typical PRPs are listed in PAS220 or FSSC 22000 but you can have more if you wish (ISO love documentation).
OPRP often = near CCP as per 7.4.4 (a-g) or perhaps an upgraded PRP.
ISO CCP = Codex CCP unless not conforming to para 7.4.4 (a-g) (when it would become an OPRP)

Slightly confused, join the club! But don’t worry too much since ISO 22004 says the choice between CCP and OPRP does not really matter anyway (as long as you hv a consistent/logical/validatable decision procedure).

@Modarres I admire the overall intention of yr plan but some of the content is rather debatable IMO. A few examples -

Q2: Is the Control Measure feasible for monitoring? Possible answer : No
IMHO, this answer causes the proposed Control Measure to be totally infeasible. End of evaluation.

Q3: Is the Control Measure's place within the system relative to other control measures?
Sorry but, as stated, the question and possible answers given have limited meaning to me. Maybe translation problem.

Q6: Is the control measure specifically established and applied to eliminate or significantly reduce the level of hazard(s)?
Define significantly.(maybe ISO should answer, the words are theirs :smile: )

Q7: Have the Control Measure synergistic effects?
Answers both agreeing and totally disagreeing with any possible importance can be found depending on the source. Not a criticism, just an observation. Perhaps the option should be equally Y or N ?

However, as suggested by ISO 22004, attempts to be too analytical regarding queries (a-g) are probably a waste of time for the user / from most auditor's viewpoints?. :smile:

Basically i think ISO simply tried to be a bit too clever. :smile:

Rgds / Charles.C


Hello,

You are talking about PRP, OPRP and CCP. What about CP (Control points) ?
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