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CCP vs oPRP in FSSC


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#1 acef2104

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Posted 24 January 2017 - 10:33 AM

Hi all,

 

We underwent a surveillance audit today for FSSC and was given a recommendation from the auditor to look again whether sieves/filters are oPRPs and not CCPs. We use sieves as a final control step and have deduced from a risk assessment/HACCP Codex tree why these were CCPs yet he insists that these are oPRPs.

 

His rationale behind it is that these have no critical limits (like time or temperature) but only set limits. He believes the function of oPRPs and CCPs are the same (i.e. you still have to action if there is an issue), however it is the limits and terminology issue are what differs from each other. 

 

What are your thoughts on this? Would like your comments!

 

Many thanks, 
 

Acef2104


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#2 Charles.C

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Posted 24 January 2017 - 11:53 AM

Hi all,

 

We underwent a surveillance audit today for FSSC and was given a recommendation from the auditor to look again whether sieves/filters are oPRPs and not CCPs. We use sieves as a final control step and have deduced from a risk assessment/HACCP Codex tree why these were CCPs yet he insists that these are oPRPs.

 

His rationale behind it is that these have no critical limits (like time or temperature) but only set limits. He believes the function of oPRPs and CCPs are the same (i.e. you still have to action if there is an issue), however it is the limits and terminology issue are what differs from each other. 

 

What are your thoughts on this? Would like your comments!

 

Many thanks, 
 

Acef2104

 

Hi ace,

 

I assume the product is food

 

Clause 10.4 of iso22002-1 suggests that the use of a sieve can be regarded as a PRP. This would appear the easiest way to resolve your disagreement.

 

If you still wish to retain sieve stage as a CCP, some context might assist, eg

 

product

process

hazard to be controlled by sieve, eg metal ?

acceptable level of hazard being controlled ?

procedure used to differentiate CCP/oprp, eg Procert tree?

critical limit(s) currently used for the sieve CCP ?.

 

IMEX the typical CCP critical limit for sieve/foreign materials is "Integrity". IIRC, iso22000 does not mandate that CLs must be numeric.

 

Nonetheless, a sieve stage typically does not allow continouous monitoring. This will exclude a CCP option for some decision trees, ie >>> oprp.


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Kind Regards,

 

Charles.C


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#3 MQA

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Posted 25 January 2017 - 11:38 PM

Back in the day when I worked in a bakery:

 

Sieve was initially a CP.  But the staff were very naughty and always damaging them.

 

Due to how severely damaged they were and how often they were being replaced we implemented the following:

  • Changed on HACCP plans from a CP to a CCP
  • Documented staff training
  • Ongoing monitoring of staff
  • Daily monitoring of sieve
  • Ongoing one on one conversations with staff
  • Staff performance review for those that refused to change
  • Due to it being a CCP, we had to implement a form to verify critical limits were being met (no damage)
  • Further staff training/monitoring/performance mgt and daily GMP audits of the new form being completed correctly and staff were being diligent and responsible
  • Changed the type of sieves being used to ensure they worked with staff.  We moved from small ones (too small and being banged against bowl, hence the damages) to a custom-made large one (too heavy therefore not being used), to building a tray holder that held the large one in place and task conducted by two people (quicker, less should strain)
  • We also: ensured suppliers of all flours delivered their Certificates of Analysis with the raw material.  Therefore: sifting was only required for certain flours, not the bulk of flour used

 

One year later, during the following external audit, the following were observed:

  • The number of damaged sieves were significantly reduced
  • Staff FINALLY understood the importance of having a working non-damaged sieve
  • Less physical contaminate issues relating to non-sifting
  • We were able to downgrade the CCP back to a CP, but left monitoring on the GMP audit

 

 


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#4 HACCP Mentor

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Posted 25 January 2017 - 11:39 PM

Hi Acef2104

 

If you have completed your hazard analysis / CCP decision tree - stick with that. It is not the auditors role to tell you what you should have as a CCP and what not to have. Their role is to assess your compliance against the assessment criteria. As long as you can justify, through hazard analysis, your decision to include or not include, that is where your focus should be.

 

If you have the sieve as your last point of control I would see the critical limit being "product must pass through operational sieve". You can then define what 'operational' means eg. intact, no holes, not damaged.

 

Just my 2 cents worth.

 

Cheers

Amanda


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