10 replies to this topic

[selminay]

Clear distinction between PRPs and Operational PRPs

The PRP's are not selected for the purpose of controlling a specific identified hazard, but for the purpose of maintaining a general hygienic production, processing and handling environment and may still have an effect on the end product safety if not included in the food safety system.

Operational prerequisites are those that are in place to directly manage or control measures that the hazard analysis has identified as necessary to control to acceptable levels and are not otherwise management by the HACCP plan.

It is therefore possible that no HACCP plan will be required. With no CCP's the main document for controlling food safety lies in the PRPs and in the Operational Prerequisite Plans.

lorne

Hi,
What do you think about Pest Control Activities. Is it PRP or oPRP?
If oPRP, we should prepare monitoring procedure, corrective actions, responsibilities and monitoring records (7.5)
Another point is do we need HACCP Plan for oPRPR?

Thanks,

[charlorne]

Hi,
What do you think about Pest Control Activities. Is it PRP or oPRP?
If oPRP, we should prepare monitoring procedure, corrective actions, responsibilities and monitoring records (7.5)
Another point is do we need HACCP Plan for oPRPR?

Thanks,

Hi

I would consider Pest control as a PRP .. a program for the maintenance of general hygienic plant conditions with its relevant scope, responsibilty, monitoring & correction.

Regarding a HACCP plan for oPRPs, no doubt, a food safety plan is needed ..

However, when after you have completed the analysis of hazards and have justified that NO CCP is present for a process step .. your control measures / activities provided by the PRPs and oPRPs for that process step can become your HACCP plan or a better description is your Food Safety Plan.
If you wish, you could make a statement relative to that on a form or table called the HACCP plan.

Cheers
Lorne

[Erasmo]

It is a PRP.
Validation is not feasible for that activity.
See ISO-22000 7.2.3

Erasmo

[Charles.C]

Dear Erasmo,

"Validation is not feasible for that activity"

As a non-user of ISO22k, am interested to know what this means ?

Rgds / Charles.C

[Suzuki]

"Validation is not feasible for that activity"

Interesting interpretation of pest control program and verification activity. Validation is certainly possible otherwise we are doing some thing that has no purpose and w/o a sense of effectiveness and I also believe it is an OPRP and as well as a PRP depending on how you shape your definition and nature of activity!

[Erasmo]

Well, that’s only an interpretation. I think validation is not feasible, or practical or viable for pest control activities.



Validation is for control measures like Metal detectors, pasteurizers, bottle washers, thermic treatments, phases or operations that are specific for controlled and specified hazard. (see definitions 3.8, 3.9 and 3.10). Validation has to be performed BEFORE the implementation of a control measure and AFTER a change in the process.



1.- Pest control activities are mentioned in 7.2.3 (PRP’s)

2.- 8.2 (Validation) mentioned only oPRP’s and CCP’s

3.- PRP’s has to be verified according to 7.8 -> and then, according to 8.4.



I hope that explain my point.



Saludos.

[Charles.C]

Dear Erasmo (and Suzuki),

Thanks for the interesting response(s).

I certainly agree that “interpretation” is one of the most commonly used terms in HACCP.

I appreciate the extracts from I22k.

The implication that validation of control measures (which are not classified as oprp or CCP) may not be required seems surprising in the sense that one of the first questions I received from the auditors of my HACCP program was to demonstrate (ie show evidence) as to the “necessity” and “technical logic” of various pre-requisite programs such as pest control, water chlorination level, etc. (of course, as a non-ISO user, there were no pre-requisite distinctions such as oprp and non-oprp required.) Seems that ISO have succeeded in muddying the water a bit.

Rgds / Charles.C

[Erasmo]

You can answer to that auditor using the criteria of clause 7.2.3 (Legal requirements, International Code of Practices, national or international standards, etc.).

In fact, in ISO 22000 the PRP’s are not really considered Control Measures (see 7.4.4 and 8.2)

Regards.

Erasmo

[Charles.C]

Dear Erasmo,

I believe you but it comes back to interpretation I guess.
After all, if the prps are not controlling anything, no real need to have them ?

Rgds / Charles.C

[Erasmo]

Dear Erasmo,

I believe you but it comes back to interpretation I guess.
After all, if the prps are not controlling anything, no real need to have them ?

Rgds / Charles.C

Of course are necessary, but only CCP and oPRP are control measures. Let’s review the definitions:



PRP

prerequisite programme (food safety) basic conditions and activities that are necessary to maintain a hygienic environment throughout the food chain suitable for the production, handling and provision of safe end products and safe food for human consumption.







operational PRP

PRP identified by the hazard analysis as essential in order to CONTROL the likelihood of introducing food safety hazards to and/or the contamination or proliferation of food safety hazards in the product(s) or in the processing environment



The word CONTROL is mentioned only in the last definition. PRPs are for maintain basic and hygienic conditions. The questions here is about the classification of Pest Control activities, and I think those activities are PRP because:



1.- It was mentioned in 7.2.3,

2.- Those activities are part of most codes of practices and

3.- Is for maintain basic and hygienic conditions.



In a FSMS you need activities to control, to improve, to verify, to maintain, for planning, etc. A FSMS is not only for controlling.



Saludos.



Erasmo.

[Charles.C]

Dear Erasmo,

I agree yr categorisations. I was just commenting that different sources may perhaps introduce some "flexibility" into the ISO text, for example can see this link, pgs 8, 9 -

http://www.nordicinn..._img/heggum.pdf

Rgds / Charles.C