I admire yr creativity.
No problem re:delays.
As per GMO, I would suggest that production of the 2 products you mention is ideally physically separated.
Accordingly I will focus on the conceptually more difficult one in the sense that no "elimination” step exists, ie salad, and view it as a separate production.
I think it’s important not to get too confused between the interpretation of hazards and control measures. eg, as GMO again, one (most likely) initial cause of , say E.coli O157 contamination, in this line is the raw material. Subsequent activities are then only capable of preventing its proliferation / cross-contamination to good material etc. So, in addition to the raw material, a specific hazard might be considered as, say, E.coli O157 growth or cross-contamination, a possible cause of the hazard being faulty hygiene practices(and perhaps no "popular" production disinfectant step). A control measure would then be either something additional to the existing hygiene setup or perhaps a correction of the original set of procedures.
I would expect that some (documented) confidence exists that the raw material arrives “free” of “headlined” pathogenic bacteria in view of above. Additionally I believe many production scenarios will include sanitising dip stations strategically located within the production area, ie a routine, additional control.
I would hope that some (validated) reason exists to suspect that the current set of prps are not sufficient to do the required “control” (ie in respect to the acceptable level as mentioned below). Although improvement is always a praiseworthy objective of course .
The 22000 basic logic/sequence of steps involved is something like –
1. Identify PRPs to create a hygienic environment suitable for the production (7.2)
2. Identify potential hazards and their acceptable levels (7.4.2)
3. Assessment (LO / severity) of all these hazards (7.4.3)
4. For hazards requiring control, select a (combination of) control measures (7.4.4)
5. Validate that the combination of control measures achieves the “acceptable” level.(8.2)
6. Categorise the combination to a HACCP plan or oPRP program.
So what is the Acceptable Level (AL) in the RTE finished product ?
I deduce that E.coli O157 is yr primary example / feared relevant microbiological species, the AL could then be a typical regulatory requirement, eg “not detected in 25g” / appropriate sampling plan (eg 5x25g samples per lot).
Assuming Nos.1-3 > significant hazard and you have proposed a No.4, the standard requires validation as per No.5, eg by a “pilot” study. (logically, one would probably hv done this for the raw material / process steps / original set-up also ?).
Assuming AL validation is acceptable, then proceed to No.6.
I could anticipate that depending on yr chosen methodology, it might be possible to (nominally) get either a CCP or OPRP result.
assuming that a significant risk is concluded, one criterion for determining the standards (self-imposed) choice between ccp/oprp might be based on the ability to define a validatable critical limit.
The microbiological CL you mention is not usually considered a viable practical option although other, faster, criteria might be used if validatable (eg by other scientific evidence / using a set of official procedures / practical result). Additionally, it is a matter of interpretation/opinion but monitoring of most of the types of (handwashing) procedure mentioned would, I think, not usually be considered compatible to the (CCP preferred) requirement of para.7.4.4b. The latter result would then probably lead to an OPRP conclusion although even this still requires “monitoring” of, presumably, a logical target.
As a literature example, I enclose a condensed FAQ reply given for a different but related situation.
This does illustrate a (positive) type answer to yr (mohanp's) original question although without giving the practical details.
Cleaning and disinfection of equipment NEP (or CIP) is it a PRP, an oPRP or CCP in ISO 22000 and why?
ISO 22000 does not predefine PRP, oPRP or CCP, but requires to define in terms of its products, processes and threats to control. It can not therefore be a single answer to this question.
The PRP are by definition to create a "hygienic environment appropriate" - without addressing a specific hazard. ( § 7.2), which sets the requirements for PRP, eg explicitly cleaning and disinfection in the aspects to be taken into account in developing the PRPs. A CIP system (or CIP) can be perfectly described in the PRP of a company.
After the hazard assessment (§ 7.4.3), § 7.4.4 requires that (combinations of) control measures should be selected to ensure control of "significant"hazards. It then applies to a specific hazard (eg. Salmonella) and not a "hygienic environment" generally.
It is conceivable at this stage that the CIP is part of the combination of control measures associated, eg a danger of salmonella in milk consumption for a large dairy.
Then and only then, the control measures of the combination will be assigned to a CCP or oPRP by a convenient and reproducible method.
In this case, given the discontinuous nature of control and monitoring possible, it is likely that the CIP should be allotted to a oPRP rather than a CCP.
I would still regard all this manouevering as a last resort compared to retaining everything as a nice, verifiable, PRP though.
Rgds / Charles.C