63 replies to this topic

[mohanp]

Could we say that hand-washing is a oPRP since it ensures removal/reduction of microorganisms?

[Tony-C]

Could we say that hand-washing is a oPRP since it ensures removal/reduction of microorganisms?

I would think it is a possibility with high risk foods. What are you manufacturing?

Regards,

Tony

[Somerset Industries]

I would imagine that you could classify hand washing as a OPRP tactic. It's a very simple thing your employees can do to cut way down on the risk of contamination. Bare minimum it is the first step.

[tsmith7858]

If you are going to call it an OPRP than you need some sort of measurement. Are you doing hand swabs or do you have some sort of verification that hand washing is effective?

[Fedal]

In 99% of caces handwashing is one of the best axamples of usual PRP (7.2.3 of ISO 22000).
Bu if your workmen are handling ready to eat product by hands (rearly in the industry) it cann get OPRP (7.5) level of controling.

[Fedal]

Probably you will have to maintain the records about each washing of your hands :))))

[Charles.C]

Dear mohanp,

yes but, as usual, it depends on yr risk analysis (as implied by Tony-C), and, perhaps, yr decision tree or equivalent method.

Also, if yr analysis is this deep, i suspect you are also going to have a very long list of additional OPRPs.

Rgds / Charles.C

[GMO]

Personally having worked in high risk I think no. The reason is you should be expecting your staff not only to wash their hands on entry to the area but after touching the floor, touching a bin, touching their face, after cleaning, before changing products etc, etc. IMO the best way to ensure that happens is training and supervision (which is classic PRP stuff) not checking each person's hands.


If you made washing your hands at entry to the plant an oPRP it then opens up the question on monitoring (and swabbing wouldn't be monitoring, it would be verification). Ok you could get one of those funky turnstyle things which only let you through once you've washed your hands but then that's taking the responsibility away from the operator and once you allow some people not to think about their hand hygiene, will they be thinking about it during their shift???

Handwashing = oPRP = can of worms and a waste of your time IMO

[Charles.C]

Dear GMO,

Handwashing = oPRP = can of worms and a waste of your time IMO

I do hope you realise that you are very close to conceptually extinguishing one of the revolutionary innovations of ISO 22000.

Rgds / Charles.C

[GMO]

i'd love to. oPRPs create an excuse for people who can't make decisions to continue to do so. 20-30 years ago you would have regularly seen 10+ CCPs in a plan, now the same is happening with oPRPs.

[Charles.C]

Dear GMO,

I presume you would be equally (or more?) critical if the OPRPs to which you are referring were classified as CCPs, ie it is the total number you are objecting to.

As per my interpretation of the text of the ISO 22000 standard, the only source of OPRPs or CCPs is the generation of “significant” hazards (SHs) (as described in sec. 7.4.3). Corresponding, validated, control measures / programs are then developed which are “sorted” into CCP-type or OPRP-type as per sec. 7.4.4.

In other words, any validated control measure which meets the requirements of the first para.of sec.7.4.4 ( ie enters the 7.4.4 box in the decision tree in ISO 22004) via a valid “logical approach” must yield either a CCP or OPRP.

An excessive number of SHs could be due to –
.
(1) Invalid logical approach for identifying significant hazards, eg , at least IMO, some implementations of the standard Codex Decision Tree.
(2) Not fundamentally incorrect but highly conservative risk criteria/procedure for identifying “significant” hazards. This is typically a question of subjectivity, eg risk matrices.
(3) Incorrect evaluation of the risk factors, eg over-conservative.

Rgds / Charles.C

[GMO]

Dear GMO,

I presume you would be equally (or more?) critical if the OPRPs to which you are referring were classified as CCPs, ie it is the total number you are objecting to.

In a word, yes.

HACCP is meant to be simple. Too many concepts and too many control points complicate matters.

[Tony-C]

IMO the best way to ensure that happens is training and supervision (which is classic PRP stuff) not checking each person's hands.

If you made washing your hands at entry to the plant an oPRP it then opens up the question on monitoring (and swabbing wouldn't be monitoring, it would be verification).

I like the concept.

Supervison = Monitoring?

[GMO]

I wouldn't accept supervision as monitoring. Where are your records? How much supervising can your average production manager do of handwashing? Anything where you're getting to a small sample is verification IMO. Having worked as a shift manager, I doubt they'd have a chance to check once a day let alone every hour or every shift changeover etc. Supervision and training would be acceptable for a PRP IMO but not an oPRP.

[Tony-C]

Having worked as a shift manager

Really? Maybe not but the best places I've worked at Supervisors and Shift Managers had checklists which I believe are records.

Edited by Tony-C, 04 July 2011 - 08:11 AM.

[GMO]

Yeah, I managed 30 people in a plant with 6 entry handwash sinks. I couldn't be everywhere. That's the problem with putting things like this onto shift managers; they really don't have the time. If your records came back beautifully completed, I can guarantee they were not done at the time.

[Tony-C]

Yeah, I managed 30 people in a plant with 6 entry handwash sinks. I couldn't be everywhere. That's the problem with putting things like this onto shift managers; they really don't have the time. If your records came back beautifully completed, I can guarantee they were not done at the time.

Sorry my previous post didn't read that well - I meant ......maybe not an OPRP.

Yes understand it is difficult as a Shift Manager but they should have Supervisors supporting them such that sufficient supervision is provided.

[GMO]

Sorry my previous post didn't read that well - I meant ......maybe not an OPRP.

Yes understand it is difficult as a Shift Manager but they should have Supervisors supporting them such that sufficient supervision is provided.

Yes but it's not the way in modern manufacturing. The idea is to have as few a layers as possible and what happens if you went the whole hog to a self managed team? What I'm trying to say is that some things lend themselves to less rigorous control because you recruit the right people and you train them (well, that's the idea) which is classic PRP stuff and if you're having to be more controlled than that for handwashing you might have to question everything as an oPRP.

[Tony-C]

Yes but it's not the way in modern manufacturing. The idea is to have as few a layers as possible and what happens if you went the whole hog to a self managed team? What I'm trying to say is that some things lend themselves to less rigorous control because you recruit the right people and you train them (well, that's the idea) which is classic PRP stuff and if you're having to be more controlled than that for handwashing you might have to question everything as an oPRP.

Be interested to know which "modern manufacturing environment" you're working in because I could'nt disagee more.

Most companies pay peanuts............

[GMO]

Be interested to know which "modern manufacturing environment" you're working in because I could'nt disagee more.

Most companies pay peanuts............

One which one the best process factory award and two more which had the best Technical results in the group and had the fewest layers of management... The reason is from an improvement point of view it often helps though to have fewer layers of management because each layer is a person to convince and a potential Chinese Whispers issue unless you communicate to each layer of management personally. Also with fewer layers you tend to be able to pay your base layer a better wage and get a better person. Yes, checking each person doing 'stuff' has it's place in a factory where people are not engaged but where they are or where you are trying to get them to be you do have to release the reins a little IMO or else you're infantilising them. If someone checks every time you go to the loo that you wash your hands the first time they're not there, the little child will see what happens if they don't do it... Do you see what I mean?

[GMO]

Sorry if I've been a bit feisty over the past few days. I think I get a bit fighty when I've had very little sleep for about 3 weeks. Got called into work yesterday (Sunday) as well when my TM is full time and I'm part time. Not impressed.

[Dr Ajay Shah]

I must say that I agree with the comments made by GMO and they are valis points.

Cheers

[Charles.C]

Dear All,

I'm still intrigued by the "Chinese Whispers" ? Audible fortune cookies ?

One side-comment FWIW is that I believe that statistically a substantial percentage of product health incidents are related to handwashing-type procedural defects.

Rgds / Charles.C

[GMO]

Chinese whispers is a game children play. You sit in a ring and whisper the first person a phrase once and then they whisper it to the next person and round in a ring until it reaches the first person who says what they heard and what it was meant to be. It always ends up as nonsense.

I was about to agree with the incidents and then I realised there hadn't been a single incident in a site I'd worked at where I'd traced it back to handwashing. In fact in one site where there was poor micro when I arrived; they'd believed it was handwashing but by doing some perito analysis I was able to prove it was vegetable cooking causing the problem. My thoughts are at some point you have to trust people have accepted your training and are responsible enough to do what they say. Of course you check this with auditing and you do put disciplinary procedures in place for anyone wilfully caught breaking the rules but practically you can't be there 24/7. You have to motivate people in a different way and I think there is a mixture of motivational tools for this; some of them positive, some negative, for example:

Positive:

Train people in handwashing
Congratulate people for doing it, especially at times they might forget, e.g. after handling rubbish
Explain why handwashing is important
Have reminder signs

Negative:

Threaten (and do) disciplinary
Have CCTV trained on handwashing stations to check for non compliance on an ad hoc basis

I would say a balance of both is necessary do drive compliance. Whenever I think about issues like this though, I think about transactional analysis. If you tell someone to wash their hands then watch them do it each time, you will get compliance but compliance like a child complies. They don't know why they're doing something they're just doing it because they're told to. If you speak to people as an adult you have more chance of them behaving like an adult (it doesn't work every time but it does help). So you explain why it's necessary, what the consequences are of not doing it, when you see someone not doing it you explain why it's wrong and ask them to correct their behaviour but do point out that repeated incidences will lead to disciplinary (it doesn't mean you can't do that). The idea is that if you 'tell' people to do something when you're not there they have no motivation to do so, whereas if they understand why they might have that motivation. I think in handwashing it's a particular case that there is no way of monitoring without very close supervision that it has to be a PRP or it's treating people like children in a way that getting someone to do a sieve check for example wouldn't be.

Does that make sense?

[Charles.C]

Dear GMO,

Here’s one audit example I encountered. A piece of fresh raw material fell off the infeed conveyor from supply truck onto the (clean) factory floor. The service person immediately picked it up and carefully washed it before adding to the (received) tray. He then continued to adjust/align items on the conveyor and wondered why all the other service personnel were glaring at him. One nonconformance without really trying.

I agree with your opinion, just because it’s a PRP doesn’t necessarily mean it’s not significant. Quite the opposite IMO.

@Chinese Whispers. Thks for the education. Must be geographical. Like I’d never heard of “kex” before I worked with a Newcastrian (?).
http://www.helium.co...orthern-england

Rgds / Charles.C