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!
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
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.