5 replies to this topic

[Mmmm_food]

I have been reading all the forums around categorising CCPs and OPRPs and even though there are a lot of conflicting opinions, have found them to be very useful in gaining an understanding in my own mind. I am now attempting to create my own methodology for categorisation but I am stuck on one of the items in 7.4.4.

Can people please explain to me their interpretation of ISO 22000 7.4.4 a) "its (a control measure) effect on identified food safety hazards relative to the strictness applied"?

Thank you

[MicroSysCo]

I think that the interpretation of this relates to a controls ability to be altered or impacted through it's implementation or management. A simpler way is to look at whether a control is either on or off or whether it has states which make it more or less effective.

Where a control is able to be on or off, where on means it is being effective at reducing or elimintating the risk, it is more likely a CCP but where it has varying states of effectiveness based on it's management or use (-Strictness) it would more llikely fall under OPRP.

Of Coarse the residual risk of an OPRP based on strictness may then raise the need for a final control with less variation based on strictness which is more likely going to be a CCP.

This may however be a complete mis interpretation (not completely unexpected with this standard),

and I am interested in how other people view it.

[Charles.C]

I have been reading all the forums around categorising CCPs and OPRPs and even though there are a lot of conflicting opinions, have found them to be very useful in gaining an understanding in my own mind. I am now attempting to create my own methodology for categorisation but I am stuck on one of the items in 7.4.4.

Can people please explain to me their interpretation of ISO 22000 7.4.4 a) "its (a control measure) effect on identified food safety hazards relative to the strictness applied"?

Thank you

Dear Chobbsy,

This para. (a) topic was discussed in more detail within drafts of the standard which preceded the final published document. As finally presented, IMO, it well illustrates the (possibly intentional) non-clarity of the HACCP portion of the standard.

ISO22004, which i assume you hv seen already, attempts to clarify the (744a) concept with by reincorporating some bits of earlier drafts. You should particularly refer to paras 7.4.4(a-d) in this guideline.

As you may hv already noticed, it is often interpreted (following the paras. referred above) in score-based, haccp CCP/OPRP procedures within iso22000 in terms of whether the proposed control measure (CM) achieves full, partial or no effect where the terms are as used in def. of a CCP.

I personally (earlier thread here) interpreted the intention of (a) as being to assess the practical capability of a proposed CM to achieve the ideal CCP objectives, or otherwise. For example, a perfect CM used for cooking might eliminate all potentially pathogenic bacteria but if this required applying a temperature of 1000degC (intensity?) then the CM would probably be of little practical value. In practice, I think most users seem to simply assess (a) as per ideas in third paragraph above or something conceptually similar.
(AFAIK, there are very few analyses of the subtleties of paras (a-g) except in the French/Scandinavian literature/books so my opinions may be quite wrong, criticisms welcome!)

The original draft formulations of HACCP for iso22000 contain some extremely elegant musings on the development of suitable control measures. Some of these are undoubtedly attempted to be expressed within the text of (a-g) paras of 7.4.4. However AFAIK, most of the "awkward" details have long been "adapted" in most routine implementations of iso22000 in favour of more simplified procedures which are nonetheless auditorially acceptable, especially to specify OPRPs. These latter procedures are presented in numerous threads on this forum.

Nonetheless you are of course only too welcome to try and improve on the existing options.

Rgds / Charles.C

[Mmmm_food]

Dear Chobbsy,

This para. (a) topic was discussed in more detail within drafts of the standard which preceded the final published document. As finally presented, IMO, it well illustrates the (possibly intentional) non-clarity of the HACCP portion of the standard.

ISO22004, which i assume you hv seen already, attempts to clarify the (744a) concept with by reincorporating some bits of earlier drafts. You should particularly refer to paras 7.4.4(a-d) in this guideline.

As you may hv already noticed, it is often interpreted (following the paras. referred above) in score-based, haccp CCP/OPRP procedures within iso22000 in terms of whether the proposed control measure (CM) achieves full, partial or no effect where the terms are as used in def. of a CCP.

I personally (earlier thread here) interpreted the intention of (a) as being to assess the practical capability of a proposed CM to achieve the ideal CCP objectives, or otherwise. For example, a perfect CM used for cooking might eliminate all potentially pathogenic bacteria but if this required applying a temperature of 1000degC (intensity?) then the CM would probably be of little practical value. In practice, I think most users seem to simply assess (a) as per ideas in third paragraph above or something conceptually similar.
(AFAIK, there are very few analyses of the subtleties of paras (a-g) except in the French/Scandinavian literature/books so my opinions may be quite wrong, criticisms welcome!)

The original draft formulations of HACCP for iso22000 contain some extremely elegant musings on the development of suitable control measures. Some of these are undoubtedly attempted to be expressed within the text of (a-g) paras of 7.4.4. However AFAIK, most of the "awkward" details have long been "adapted" in most routine implementations of iso22000 in favour of more simplified procedures which are nonetheless auditorially acceptable, especially to specify OPRPs. These latter procedures are presented in numerous threads on this forum.

Nonetheless you are of course only too welcome to try and improve on the existing options.

Rgds / Charles.C

Thanks for your reply Charles. I have read 22004 but find that is does not clarify anything for me. I have looked at all the simplified procedures for categorisation that others have created and am incorporating aspects from each one when creating my own. My motivation for creating yet another method is so that I am clear in my own mind how decisions on CCPs and OPRPs are reached and can be confident in justifying the process to an auditor.

My interpretation of 7.4.4 a) is whether the control measure is effective in the given situation. For example a control measure could be a well known and proven control measure but in a particular process (and/or the point in the process) is it effective? Your interpretation in the fourth paragraph seems similar but maybe I have misunderstood you?

[Charles.C]

Dear Chobbsy,

My philosophical interpretations (FWTW) of par(a-g) et seq are more or less contained in this post.-

http://www.ifsqn.com...dpost__p__36566

Two popular recurring confusions between OPRP and CCP are that –
(1) an OPRP must be a “PRP”.
(2) An OPRP is a kind of 2nd class CCP.

The first one partly (semantically) derives from the pre-final terminologies of PRP/OPRP.
The 2nd one derives from the typical method(s) of categorisation which can appear in contradiction with specified text in iso 22004 (which implies that the ranks are in fact equal). Perhaps you don’t agree.

Frankly, I think most people have abandoned analysing the original ISO22000 minutiae and simply select the most readily implementable technique for distinguishing OPRP/CCP which is also auditorially acceptable. Sadly, AFAIK, most of the few recent published discussions are in French language only (I posted one decision tree of theirs in another thread here). I nonetheless wish you good luck for yr enterprise.

Rgds / Charles.C

[Tony-C]

I have been reading all the forums around categorising CCPs and OPRPs and even though there are a lot of conflicting opinions, have found them to be very useful in gaining an understanding in my own mind. I am now attempting to create my own methodology for categorisation but I am stuck on one of the items in 7.4.4.

Can people please explain to me their interpretation of ISO 22000 7.4.4 a) "its (a control measure) effect on identified food safety hazards relative to the strictness applied"?

Thank you

Hi Chobbsy,

With regards to a) effect on identified food safety hazards relative to the strictness applied. Using thermal processing as an example each organism (hazard) will have a different susceptibility to heat/time. Usually this is represented by a D-value.

In the food industry, it is important to reduce the amount of microbes in products to ensure proper food safety. This is usually done by thermal processing and finding ways to reduce the number of bacteria in the product. Time-temperature measurements of bacterial reduction is determined by a D-value, meaning how long it would take to reduce the bacterial population by 90% or one log10 at a given temperature.

The end result will depend on other things including any other microcidal factors (pH, preservatives) and inactivation steps (synergism) plus initial loading. Whether this is a CCP may depend on each individual process as you have indicated for example if there is a likely recontamination.

There are other factors in thermal processing such as monitoring and likely failure which could be different for example batch vs. continuous processes.

My view is there is not a ‘one fits all’ solution, your hazards, control measures, process and position of control measures may be unique and as such you need to assess the effects of the control measures. Thus when following ISO 22000 7.4.4 guidelines you should take into consideration the control likely to be achieved following a) to g) requirements rather than a) in isolation.

Kind regards,

Tony