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Making the Switch BRC -> FSSC22000

BRC FSSC22000 FSMS

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#1 it_rains_inside

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Posted 20 June 2014 - 12:52 PM

Im wondering how hard it is to make the switch. Our Corp Quality Director has been talking plans about converting us from BRC to FSSC22000 (apparently she feels that FSSC is where the industry is heading...??) With Version 7 on the brink of being released, it seems to be the appropriate time (if any) to go for it. 

I have very, VERY little ISO experience, so Im throwing this out - Has anyone else made the change? How did it work out? What was easier/harder? If Im gonna make a case either way, to stick with BRC or make the switch Id like to have some insight from the people who know the best (Thats you guys!!)

 

Thanks in advance for the help!


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#2 Charles.C

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Posted 20 June 2014 - 04:05 PM

Rear itrainsinside,

 

I am almost certain yr exact question has been asked at least once before, if not more. May be worth searching.

 

The unhelpful answer is that the 2 systems are different. Predictably less so if you have ISO experience. Some aspects are "easier" since ISO-style is less definitive in its requirements (however non-ISOists may regard this feature as being more difficult to get to grips with [my own experience]). Good Company money saver though - no revision in 9 years.

 

You will have to somewhat relearn haccp and especially vis-a-vis prerequisites and OPRPs. You might have a look at the model haccp analysis of yoghurt presented on this forum for FSSC22000 which give some implementation ideas / differences to traditional haccp.

 

Rgds / Charles.C


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Charles.C


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#3 it_rains_inside

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Posted 23 June 2014 - 02:42 PM

Charles C.

 

Thank you for pointing me in the right direction. I found the thread about transitioning and also the yogurt model - Very helpful!!  I've taken courses on other FSMSs and how they are similar / different - But the only system I have ever really built is geared towards BRC. Honestly, although it seems to be the most rigid of the options, for someone new(er) to Food Safety, the structure has helped me in being confident about my system. 

 

FSSC seems to be more of an interpretive system, and the OPRP/ CCP situation looks like a downright mess to me! I would love to stick with BRC because it is what i am comfortable with - I was just looking for back-up for when this conversation is initiated by my boss, and if it is in fact better for the business, what I should be prepared as far as making the changes. I agree - relearning HACCP seems to be the biggest hurdle. 

 

Thanks again!!


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#4 Tony-C

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Posted 24 June 2014 - 02:28 PM

Charles C.

 

FSSC seems to be more of an interpretive system, and the OPRP/ CCP situation looks like a downright mess to me! I would love to stick with BRC because it is what i am comfortable with - I was just looking for back-up for when this conversation is initiated by my boss, and if it is in fact better for the business, what I should be prepared as far as making the changes. I agree - relearning HACCP seems to be the biggest hurdle. 

 

Thanks again!!

 

Hi there,

 

If you have BRC certification you are likely have covered the prerequisite requirements and food safety management aspects. As Charles has indicated you will need to revisit your HACCP but assuming you have HACCP plans already this shouldn't be too onerous. The main thing is to get a clear vision of how you are going to decide if control of a hazard is by OPRP or is a CCP and controlled as per the HACCP plan.

 

Some extracts from the OPRP Training Presentation in the new IFSQN FSSC 22000 Food Safety Management System for Food Manufacturers Package may give you some ideas.

 

Attached File  Operational Prerequisite Programme Training Guide 2014.pdf   5.81MB   97 downloads

 

Regards,

 

Tony


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#5 Charles.C

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Posted 25 June 2014 - 06:50 AM

Dear it rains inside,

 

I can add a little background to Tony’s interesting post.

 

I think you will appreciate that any FS methodology invoving risk assessment / risk probabilities such as HACCP is inevitably going to be subjective as far as (a) determining hazards which need to be controlled, eg the “significant” ones and then (b) selecting  appropriate control measures for the hazards chosen.

 

Codex/NACMCF published summaries of their, developed, methodologies in the 1990s which remain the basis of most “traditional” HACCP methods.

 

ISO developed/presented a modified approach in ISO22000-2005 focusing (with respect to HACCP) on categorising control measures into Prerequisites / CCPs (using the term loosely) / OPRPs. The control  measure/function/program OPRP was introduced to allow/manage for certain hazards which were not readily handled by the, then, current HACCP  procedures such as referred above.

 

Defining/selecting OPRPs was an immediate source of controversy in FS-HACCP circles and was attempted to be further rationalised by ISO via their near-simultaneous release of the 22004 technical “Guide”. This did explain/simplify certain aspects but unfotunately blurred over specific expectations for identifying OPRPs so that the arguments continued to reverberate. Sadly, AFAIK,  ISO never published any “worked examples based on their standard, presumably from fear of  creating a precedent over subjectivity. Conceptual/practical debates over the correct/best methods of interpreting/finding OPRPs continue up to today.

 

Based on threads in this forum, FS Auditors from the beginning of ISO 22000 have apparently felt obliged to accept any procedure based on a “logical” and “validatable” interpretation of the ISO/FSSC text  which yielded an effective mixture of PRPs / CCPs / OPRPs, ie gave a satisfactory result with respect to consumer Food Safety (there are likely to be some geographical caveats in the preceding comment). The later release of the ISO list of (preferred) Prerequisites has  considerably aided the PRP segment of ISO-FSSC 22000.

 

In practice the "HACCP" methodologies published/utilised for ISO-FSSC range from short to lengthy, very simple to highly intricate. And a similar comment regarding the eventual numbers of CCPs/OPRPs involved. History tends to repeats itself ?.

 

Rgds / Charles.C


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Charles.C


#6 Tony-C

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Posted 25 June 2014 - 07:11 PM

Dear it rains inside,

 

I can add a little background to Tony’s interesting post.

 

I think you will appreciate that any FS methodology invoving risk assessment / risk probabilities such as HACCP is inevitably going to be subjective as far as (a) determining hazards which need to be controlled, eg the “significant” ones and then (b) selecting  appropriate control measures for the hazards chosen.

 

Codex/NACMCF published summaries of their, developed, methodologies in the 1990s which remain the basis of most “traditional” HACCP methods.

 

ISO developed/presented a modified approach in ISO22000-2005 focusing (with respect to HACCP) on categorising control measures into Prerequisites / CCPs (using the term loosely) / OPRPs. The control  measure/function/program OPRP was introduced to allow/manage for certain hazards which were not readily handled by the, then, current HACCP  procedures such as referred above.

 

Defining/selecting OPRPs was an immediate source of controversy in FS-HACCP circles and was attempted to be further rationalised by ISO via their near-simultaneous release of the 22004 technical “Guide”. This did explain/simplify certain aspects but unfotunately blurred over specific expectations for identifying OPRPs so that the arguments continued to reverberate. Sadly, AFAIK,  ISO never published any “worked examples based on their standard, presumably from fear of  creating a precedent over subjectivity. Conceptual/practical debates over the correct/best methods of interpreting/finding OPRPs continue up to today.

 

Based on threads in this forum, FS Auditors from the beginning of ISO 22000 have apparently felt obliged to accept any procedure based on a “logical” and “validatable” interpretation of the ISO/FSSC text  which yielded an effective mixture of PRPs / CCPs / OPRPs, ie gave a satisfactory result with respect to consumer Food Safety (there are likely to be some geographical caveats in the preceding comment). The later release of the ISO list of (preferred) Prerequisites has  considerably aided the PRP segment of ISO-FSSC 22000.

 

In practice the "HACCP" methodologies published/utilised for ISO-FSSC range from short to lengthy, very simple to highly intricate. And a similar comment regarding the eventual numbers of CCPs/OPRPs involved. History tends to repeats itself ?.

 

Rgds / Charles.C

 

As I said in much fewer words 'get a clear vision of how you are going to decide if control of a hazard is by OPRP or is a CCP and controlled as per the HACCP plan'

 

We have one at IFSQN!   :k9:

 

Regards,

 

Tony


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#7 Charles.C

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Posted 25 June 2014 - 10:48 PM

As I said in much fewer words 'get a clear vision of how you are going to decide if control of a hazard is by OPRP or is a CCP and controlled as per the HACCP plan'

 Hi Tony,

 

Perhaps a "significant" hazard ? (although the interpretation of "significance" within an ISO22000 context is not necessarily the same as for traditional HACCP  perhaps ?)

 

Rgds / Charles


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#8 Tony-C

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Posted 26 June 2014 - 02:30 PM

 Hi Tony,

 

Perhaps a "significant" hazard ? (although the interpretation of "significance" within an ISO22000 context is not necessarily the same as for traditional HACCP  perhaps ?)

 

Rgds / Charles

 

Hi Charles,

 

I see your point and another 'greyness' in the ISO 22000 standard clause 7.4.3 Hazard assessment:

'Each food safety hazard shall be evaluated according to the possible severity of adverse health effects and the likelihood of their occurrence. The methodology used shall be described, and the results of the food safety hazard assessment shall be recorded.'

 

But the standard doesn't proffer methodology, although the TECHNICAL SPECIFICATION ISO/TS 22004 Food safety management systems — Guidance on the application of ISO 22000:2005 elaborates a bit more:
'In conducting the hazard assessment, the following should be taken into consideration:
a) the source(s) of the hazard (e.g. where and how it can be introduced into the product and/or its environment);
b) the probability of occurrence of the hazard (e.g. qualitative and/or quantitative prevalence, such as frequency of occurrence and the typical levels, highest possible levels and/or statistical distribution of levels);
c) the nature of the hazard (e.g. ability to multiply, deteriorate and produce toxins);
d) the severity of the adverse health effects that can be caused by the hazard.'

 

IMO the result of the evaluation is identification of significant hazards

 

Regards,

 

Tony


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#9 Charles.C

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Posted 27 June 2014 - 01:11 PM

Hi Tony,

 

I am in agreement with the chronology/interpretation for determining “significance” as shown in  yr previous attachment.

 

However i was puzzled regarding 2 onward aspects in the above attachment –

 

(1) I didn’t see any reference to “validation”. As per fig3/22004 it is required to validate any proposed control measure before proceeding to 7.4.4. (This was an “error of omission” in the original standard). Logically this will exclude certain data entries in columns J-P. (similarly to the pre-derived  status of “Significant hazard”).

 

 

(2)  I was unable to figure out the reason why data generated/analysed in columns J-P (ie equivalent to the standard’s 7.4.4) might require further use of the Decision Tree shown. As a corollary of (1) it seems to me that any validatable control measure for a significant hazard must  (minimally) yield a CCP (ieYY) if submitted (I appreciate this may conflict some of the data shown in the attachment). However a different result, ie OPRP, is possible from columns J-P depending on the applied criteria ( the term "effective" seems to be particularly popular / utilised in various ways, eg def.validation of CCP/OPRP, in the ISO documents, possibly another ISO grey area).

I daresay the explanation to (1,2) is in the details of the source document. Or (equally possible) i have misunderstood the text. :smile:

 

Rgds / Charles


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