Thanks for Charles and FurFarmandFork for the useful posts.
Technically if the filter is to remove a foreign body choke hazard then this could be a
CCP. Given the nuances of 22000 for the assessment of control measures one could make a case for PRP, OPRP and
CCP.
Typically in most processes I have carried out this assessment the filter has been controlled as an OPRP, a maximum size specified, the filter to be check to ensure it is in place, seated properly and intact (at start and end of production run)
When we come to Clause 7.4.3 Hazard assessment onwards we need to decide if control measures for a hazard fall into the category of needing to be controlled through operational PRP(s) or by the
HACCP plan.
Clause 7.4.4 Selection and assessment of control measures elaborates further:
The selection and categorization shall be carried out using a logical approach that includes assessments with regard to the following:
a) its effect on identified food safety hazards relative to the strictness applied;
b) its feasibility for monitoring (e.g. ability to be monitored in a timely manner to enable immediate corrections);
c) its place within the system relative to other control measures;
d) the likelihood of failure in the functioning of a control measure or significant processing variability;
e) the severity of the consequence(s) in the case of failure in its functioning;
f) whether the control measure is specifically established and applied to eliminate or significantly reduce the level of hazard(s);
g) synergistic effects (i.e. interaction that occurs between two or more measures resulting in their combined effect being higher than the sum of their individual effects).
Control measures categorized as belonging to the
HACCP plan shall be implemented in accordance with 7.6. Other control measures shall be implemented as operational PRPs according to 7.5.
As Charles has pointed out there is a need to have a limit or to specify a standard in order to comply with 8.2 Validation of control measure combinations.
There is limited information available to specify acceptable limits for foreign bodies, the FDA previously published guidance for seizure based on an object being 7 - 25mm, RTE and not for special groups. Clearly your specified filter sizes are more than acceptable by this standard. Some useful info here:
If we take glass as the hazard then this hazard could be controlled by a combination of glass policy, glass checks, breakage procedures and filtration.
The important thing for me is not the classification of the control measure but that the hazard is adequately controlled.
Kind regards,
Tony