Dear jcri,
Thought I should add a little more explanation. Apologies in advance if you know all this already.
The penultimate versions of ISO 22000 included oprps for certain specific sanitation control aspects and in principle, as you stated, the standard still maintains such a possibility, especially where there is a significant hazard envisaged. (In fact there is a lengthy (conceptual) thread on this forum discussing the possibility of “handwashing” being an OPRP ). The final published version of the ISO2200 standard incorporated a few apparent "re-thinks" regarding the interpretation / determination of oprps, the typical user result being, IMHO, confusion. ISO shortly issued ISO 22004, a "Guidance" document which included some clarifications regarding categorisation of oprps. Another ISO document (2006) discussed the intended scope / sourcing of oprps -
ISO22000 blanc 2006 - some comments on implementation.pdf 275.29KB
397 downloads
Since, AFAIK, the idea of Prerequisites is hopefully to simplify the design of the FSMS, it is initially preferable IMO to simply follow the logic of the standards clause on selecting Prerequisites and include the operational aspects you mention within the prerequisite program(s).
A significant failure in the performance of a prerequisite will typically be highlighted within the “Verification” function so that further responses can be applied as per the relevant standard’s clauses, eg reviewing/revising/updating the HACCP plan as appropriate.
It is also true as you noted that traditional HACCP/CCPs tended to rely on readily quantifiable critical limits, the absence of such being one motivation for the invention by ISO22000 of OPRPs. However the lack of critical limits can be somewhat of a “red herring” since in practice it is rather difficult to validate control measures without some form of “operational” criteria, be it qualitative or quantitative.
Nowadays, the specific determination of OPRPs usually tends to initially focus on the text starting at clause 7.4.4 after determining the significant hazards from the hazard analysis (7.4.3). IMEX, it is tacitly assumed that if a prerequisite function is satisfactorily implemented, it’s associated safety risk will be non-significant due to a low likelihood of occurrence. (in a sense, the prerequisite option acts as a “by-pass”, early HACCP plans without prerequisite functions often had “Sanitation” CCPs all over the place).
PAS220, now known as ISO/TS 22002-1, represents a jumbo compilation of GFSI, and “ISO- acceptable” Prerequisites, but postdates ISO22000. However it now seems to also be in use as a support document to ISO22000 in addition to FSSC22000 ( ), (eg –
http://www.22000-too...mmes-22002.html ). PAS220 specifically includes CIP.
Hope the above is intelligible/useful.
Rgds / Charles.C