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#1 Penard

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Posted 21 November 2007 - 05:57 PM

"""Dear Charles,
Following requirements of ISO 22000 imply that OPRPs are equivalent to CCPs in terms of monitoring, corrective actions, verification and recordkeeping

ISO 22000 requirements :
7.5 c) monitoring procedures that OPRPs are implemented.
7.5 d) corrections and corrective actions
7.5 f) records of monitoring
7.6.4 System for monitoring of critical control points
7.7 updating of preliminary information and documents specifying the PRPs and HACCP plan - (THIS IS I THINK a TYPHOGRAPHY ERROR, BECAUSE, PARAGRAPH BELOW (7.5) IS TALKIN ABOUT OPRPs NOT PRPS)
in 7.8 Verification planning a) PRPs are considered sepately however,
7.8 c)OPRPs and HACCP plan(CCPs) are considered together.

Most certain one is
7.10.1 the organisation shall ensure that when critical limits of CCPs are exceeded
OR there is a loss of control of OPRPs, the products affected are identified and controlled...
7.10.1 clearly show us the main difference is "critical limits" I think :)

7.10.2 Data derived from the monitoring OPRPs and CCPs shall be evaluated by designated persons with ....
This is not a certain requirement for ordinary PRPs.

Requirement 7.10.2 suprisingly relates only to OPRPs and CCPs but not to ordinary PRPs.


Corrective actions related to PRPs is required if any problem is found during internal audits or verification.(in Req. 8.4.1/last paragraph, 8.4.2c)

An other thing is the difference between PRPs and OPRPs :
Yes, OPRPs are also PRPs BUT...
They are specific PRPs equivalent to CCPs in terms of monitoring, verification, correction, corrective actions and recordkeeping.
Ordinary PRPs are not a matter of monitoring or corrections, they are only subjected to Verification by 7.8a).


Should we discuss this in a separate topic what do you think?

Kind regards.

Kara

This post has been edited by downtown: Today, 12:50 PM """


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#2 Penard

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Posted 21 November 2007 - 06:10 PM

Hello Downtown,

Such an interesting proposal I can't resist creating a new topic...

First, concerning ISO 22000 requirements, 7.7, there is no typography error to my mind - I have the french version, the same 'mistake'. I don't understand this point in the same way : to my mind you have on the one hand the Haccp plan with OPRP and CCP, and on the other hand PRP.

So for instance when you have to update your Haccp plan, first you have to check your PRP, second you can begin your Haccp study.

Concerning the rest of your point of view I totally agree with you, oPRP allows us to make real and right differences between good manufacturing practices and CCP, even if it's difficult to learn. Just an example about 22K and its importance, french inspectors - the 'vets' - apply this new decision tree, and french factories will have too in the future,

Regards,

Emmanuel.


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#3 downtown

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Posted 21 November 2007 - 08:06 PM

Emmanuel,
Thank you for opening this new thread. Since I was afraid of opening too many topics, I didn't prefer to open a new one and answering to the Charles was important too.

Second also thank you for your valuable comment, Yes I have to correct this. I am now agree with you. 7.7 is about both HACCP plan and PRPs when we take care of last paragraph. However, in the first line of the first paragraph is indeed talking about OPRPs. :unsure: This paragraph is about update of FSMS so it could refer to PRP, OPRP and HACCP plan(CCPs).

Charles, Simon and other colleagues , please help us in this topic. Let us develop mature ideas about the standard together here.


Edited by downtown, 21 November 2007 - 08:08 PM.

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#4 Charles.C

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Posted 22 November 2007 - 12:54 AM

Dear Emmanuel and Kara,

Wow! Reading these posts is like seeing a new language developing. :thumbup: Unfortunately I don't yet have the dictionary :smile: .

Nonetheless I am full of admiration at yr in-depth appreciation of I22k standard. I will try and re-read the standard(s) to make an intellligent comment.

Frankly, on my previous reading I had concluded a, probably, far too simple interpretation that the intention of standard was to initially require a selection of a whole range of system-wide hygiene-GMP-type items as per def. 3.8 and listed in 7.2.3 ( a - j, accepting / ignoring the ambiguous "k" ) and then label these to be PRPs (sort of analogous to traditional / current HACCP PRPs [added - admittedly some of the traditional approaches are also quite flexible in their introduction of pre-requisites, eg receiving materials ].
Next , my interpretation was to carry out a traditional HACCP risk analysis and select the CCPs and oPRPs based on an (obviously subjective as usual) 3 - tier risk scenario/matrix so that the middle tier which would typically be dropped in the "old' HACCP type scheme would now be oPRPs (although I had realised the def 3.9 is phrased with considerable (intentional?) ambiguity :angry: ). I appreciate all the categorisation distinctions as referred in preceding posts but I had thought these were more of a corollary to the over-riding risk assessment rather than a primary decider. Now I'm not at all sure.
The above logic appeared to match the text in (22004) ie 7.1 (a) and (b) but not the content of various posts already appearing in this forum.
I am waiting with interest to see a fully worked out example anywhere.

Sorry for digression, I will now return to studying previous posts so I can maybe comment further.

Rgds / Charles.C


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Charles.C


#5 porky

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Posted 28 November 2007 - 06:18 PM

Dear All,

Allow me to create some confusion… :whistle:

Most of the companies I know are still using the Codex decision tree to create the difference between OPRP and CCP.
I personally do not agree with it :dunno:
I challenge you to show me that the tree “answers” the 7.4.4 of the standard, I’m open mind person but still nobody could convince of that correspondence.

Hope to hear your thoughts :rolleyes:


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#6 Charles.C

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Posted 29 November 2007 - 08:07 AM

Dear Porky,

Very nice to hear from you again.

Allow me to create some confusion

I much doubt that you can cause more confusion than I22k has already generated on its own. :smile:


I personally do not agree with it


I presume you are particularly referring to last step in Figure3 of ISO 22004
In what respect do you not agree ?

Although the requirement is quite well hidden even in traditional HACCP, I think the Ctree still in principle demands an explicit risk analysis somewhere although it is a fact that in practice this is often (a) not shown, or (b) crudely interpreted, or © simply by-passed altogether.

If you are saying that I22k offers no explicit way to decide from the (presumed) done risk analysis as to whether the step/control measure is to be considered a CCP or an oPRP, I can only agree. However this criticism is almost inevitable since all risk analyses are subjective and often specific to the particular process (and the specific HACCP experts :smile: .) The final “guide’ comments in the last para. of 7.4.4 (I22004) (ie “…the higher ….the more likely …..” and the “more severe…..the more likely” almost shout this out. I suppose a preceding comment also defines that considerable flexibility in interpretation should be "acceptable" (ie "the organisation may focus .... many ...operational PRPs and.... few ...HACCP plan ..... or the opposite" . I find this a very odd statement personally simce it appears opposed to the usual desire to minimise the number of CCPs.

Now you can tell me I have misunderstood yr post and recycle the confusion. :biggrin:

Rgds / Charles.C

added - :oops2: :oops2:

After a more careful look at yr post / I22k documents, I guess my post over-simplified the intent of yr query and that you were comparing the decision making ability of 22004 tree to 7.44.a,b,c etc in I22k which represents a much enlarged "challenge". Sorry. Actually, as I re-read the last part of I22004, sec.7.4.4 again, I get the feeling that the closing chunk ("guide") is an attempt to prioritise the above a,b,c's etc.

Hope the experts (Emmanuel / Kara ??) out there aren't chuckling too much at these amateurish musings. They are very :welcome: to respond.

I googled around this topic a bit and seemed to me that the French websites like AFNOR are much more heavily into this standard than UK with detailed questions on the I22k content similar to above getting specified answers (or perhaps "attempts" at answers but at least offered :smile: ). Don't know if this reflects a strong French driving force for this standard (anti - BRC perhaps ;) )
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Charles.C


#7 Penard

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Posted 02 December 2007 - 06:49 PM

Dear all,

Very interesting replies! I'm not an expert (sorry!)but I would like to answer these replies.

Porky, that's right, most of the companies still use the codex decision tree. But it's just an example, then you have to change the decision tree to be compliant with a lot of things -your process, suppliers...And I'm not sure each company is always right with its decision tree (codex or 22K), but to me, the most important is to be compliant with good manufacturing practices and hazards analysis - real change for our factories compared to few years ago!

Second, I'm ok, we have no decision tree with 22K. That's just my opinion, our 'codex' experience helps us a lot to understand 22K -it seems to me quite difficult to begin a Haccp study without these experiences.
Therefore we have to get used to working in other ways. Moreover, in most cases we don't have concrete examples in regulatories,ISO systems, or anything else. That's why certification usually depends on your inspector...and that is the reason why it's difficult from the time being to have clear ways of thinking. But I must confess it's much more easier to understand 22K now than 2 years ago.

Concerning the 7.4.4, we have to understand that oPRP is a prerequisite programm - a sensitive manufacturing practice - and CCP a critical control point.
So I agree with Porky, you don't have to test oPRP with a decision tree, but with its own 'decision tree'. Right, not clear to talk about oPRP in danger analysis with the CCP's.

But you don't have the same monitoring procedure CCP/ oPRP as the 7.4.4 explains it (maybe it's clearer in the french version, I try to translate, "you have to class your monitoring plan depending on oPRP OR CCP").

So the main difference with 22K is to admitt not to have only 'classical' CCP such as cooking temperature, foreign bodies etc... but also oPRP from GMP such as very cleaned hands and very cleaned materials for sliced smoked salmon, with a different monitoring plan.

Regarding to 22K, you always have to keep in mind : well what is it, a CCP or a oPRP? And continue your study.
But that's right, you don't have real differences in CCP and oPRP analysis. I hope future versions will be clearer, it would be easier and more efficient for everybody...

Last, you're right Charles, french people are very interested in this quality system, regarding to officials and factories.

Hope I answered some of your questions,

Regards,

Emmanuel.


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#8 downtown

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Posted 03 December 2007 - 10:11 PM

Let me add something to Emmanuel about decision tree.
Decision tree is only a tool that will help you to find your way.
In doing a HACCP study, experience is CRUCIAL! In most situations, you draw the line first and then put the points on it in contrast to general opposite thought. :)

I mean you make a decision first then you use the tools such as decision tree to support your decision.

Let me explain how : First of all we should always think if a particular hazard is very possible to make the customer ill or hurt. (your teams experience and considering statistical data such as customer complaints), this situation will encourage you to answer the questions in the tree so as to find a CCP here. ^_^

When you use a mathematical model like (severity x likelihood = Risk) as mentioned in definition of risk in codex alimentarius, this formula will also confuse your mind and give wrong results to you since...

There is something missing in this classical definition. Indeed, likelihood is only probability of this hazard to occur but we need more to be sure of this hazard we need to learn measures taken to detect or prevent this hazard from reaching the market or the consumer.

For example if a company buys a metal detector, severity and likelihood of metal contamination to product stays same but detectability of this hazard increases dramatically assuming effective operation.


Yes, this sounds very familiar to some colleagues, this is FMEA (Failure Modes and Effects Analysis)

Severity, which rates the severity of the potential effect of the failure.
Occurrence, which rates the likelihood that the failure will occur.
Detection, which rates the likelihood that the problem will be detected (or prevented) before it reaches the end-user/customer.

Please note that as capablity of detection increases, the score you give to it reduces unlike severity and occurence.

Risk Priority Number= Severity x Occurence (likelihood) x Detection(or prevention)
Resource : http://www.reliasoft...2q2003/rpns.htm

As I tried to explain in some of my previous postings, HACCP is a simplified derivation of this very old FMEA technique used by automotive industry for many decades.

Regards.

Kara


Edited by downtown, 03 December 2007 - 10:50 PM.

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#9 Penard

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Posted 12 December 2007 - 12:22 PM

Hello,

Completely agree with downtown, nothing to add; does anyone have statistics about ISO 22000?

Regards,



Emmanuel.


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#10 Charles.C

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Posted 13 December 2007 - 03:20 AM

Dear Emmanuel,

I will take the (intentional? :smile: ) bait. (Had intended to revert earlier but no time to take a close look at FMEA.)

Regretfully my knowledge of FMEA is limited but I don't really agree with Kara's comments which seem to imply that HACCP's basic defects mean that it is not suitable to be used ( perhaps I have misunderstood ?).

All these procedures are I think descended from the subject of Risk Analysis which in its full mathematical rigor is probably quite unintelligible to the normal user like myself.

I have never used FMEA however I suspect there are some specific reasons why it is not much used in the food industry. Perhaps the intrinsic variability level and difficulty in closely quantitating food parameters is involved ?

There is a brief thread on this topic (with Excel example) in this forum and I seem to remember the complexity of implementation rather dismayed the (narrower minded maybe) food oriented readers ( perhaps "car" people have more fascination with such systems ).

I agree with Kara about the difficulty in using risk matrices but I think the reason is simply that very few practical examples are available in the open information sources like IT. This is also an accusation to the Codex tree procedure IMO in that it invites people to jump the initial process evaluation. (I have similar opinions with respect to ISO22k! - someone once said "if you can't measure it, it doesn't exist" just replace "measure" by "understand" :thumbdown: )(although I am obliged to accept that my wife exists :whistle: .)

Actually the effect in HACCP analysis of whether, for example, a metal detector exists or not in the line is accounted for in some HACCP procedures (not all maybe) although admittedly not in the same quantitative style as FMEA would presumably require.

I am still struggling with some of the opinions in previous posts - such as that hand cleaning is an oPRP. I would have thought this was a perfect example of a PRP, and also a non-oPRP. So much for my understanding at this moment.! :biggrin:

I am also curious as to the "official"language presentation of ISO22k. Seems that there may be specific conclusion differences in the text depending on whether interpreted in French / English, (or perhaps some items are not accurately cross - translated in the existing published versions.)

Regards / Charles.C


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Charles.C


#11 downtown

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Posted 13 December 2007 - 10:46 AM

Dear Charles C.,

I would like to answer only one thing for the time being :
Hand washing.
First of all let us concur in one thing :
- all OPRPs are PRPs too, but reverse is not correct at all.

So I must clear myself : Hand washing is always a PRP. But according to me , in some circumstances such as cold sandwc. prep. and smoked solmon packing, it is indeed an OPRP.

Let me give an other example. Suppose that you learn Kara is a gentleman , after a short talk with him you learn that he is a gentleman with a black hat . Indeed, this situation does not change the fact he is still a gentlemen among the others without a hat :)

I mean being more categorised than the others does not make it apart from the main category.

I can even prove this by using both FMEA and HACCP risk analysis formulas with numbers. and possibly with HACCP decision tree.

Kind regards.

Kara


Edited by downtown, 13 December 2007 - 10:48 AM.

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#12 Penard

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Posted 13 December 2007 - 12:51 PM

Dear Downtown and Charles,

Charles, I hope you will agree with downtown's example! Right, oPRP/ PRP are every difficult to understand, and usually you only can 'measure' :biggrin: the differences by a real '22K' Haccp study.

A french passionate discussion forum deals with it regularly, and we realize there still are a lot of misunderstandings. So don't worry! You're not the only one to have some problems, but you try to understand it, so 'chapeau' (it means 'right, guy, congratulations!')

Concerning FMEA, I don't use this method but some colleagues of mine use it; I think you must have a very good knowledge of your product and process before using it.

Last, concerning french version, I'm lucky because it's my native language, it would have been much more difficult for me to read and understand it in another language. Reason why it's easier to understand some difficult words!

Regards,

Emmanuel.


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#13 Charles.C

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Posted 15 December 2007 - 01:48 PM

Dear Kara / Emmanuel,

One thing I like about this thread is that it is now focussing on (very) basics which is where the untrained 22K people like myself tend to get stuck, I think.
I am exceedingly grateful that you both have the patience to try and clearly explain these things. Please forgive me if I continue at this level for the moment.

- all OPRPs are PRPs too


You may be correct but I don't see it following from the definitions in the I22k standard (??).

I will try and find some examples in the IT to validate yr statement (or not :biggrin: )

So I must clear myself : Hand washing is always a PRP. But according to me , in some circumstances such as cold sandwc. prep. and smoked solmon packing, it is indeed an OPRP.


I think (??) you are saying that based on the hazard analysis, you have decided that the risk significance of (improper) hand cleaning at a particular step in the named process is so high that the operation (although already covered within a main PRP category of personal hygiene) requires elevating in status to an "oPRP". I personally have no big problem with that subjective decision although it seems un-neccesary I think ? (Such logic caused many multiple sanitation CCPs in the early traditional HACCP schemes). However, I can see the possibility of perhaps requiring some unusual additional sanitising procedure for that specific step and calling that an oPRP but then it should not be classified within the general routine hygiene category (or should it ?? :smile: ).

Maybe I've misunderstood all this in which case sorry again but still excedingly grateful for the dialog.

I shall take care to avoid people wearing black hats in the near future. :thumbup:

Maybe I also have some French blood somewhere in the past!. :rolleyes:

Rgds / Charles.C
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#14 downtown

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Posted 15 December 2007 - 09:56 PM

Dear Charles C,

Let us discuss this by using the same example : Sandwiches preparation with hands

Suppose you realised hands of an employee are very dirty from swabs and there are 10 sandwiches in the box. What to do?
You do have to
- do correction in products (discard)
- do a product withdrawal or perhaps a re-call.
- record this situation
- Corrective actions (Training of employee, etc.)
( Those things above are mandatory for OPRPs and CCPs not for PRPs :) )

In case of such a failure, there could happen microbiological disasters, you know this could be a canteen of a primary school. An other thing is the fact perhaps this employee touched to a poisonous chemical unintentionally and forgot to wash his hands.
So, you have to monitor hand hygiene of employees in such a situation.
MONITORING is mandatory only for OPRPs and CCPs not for PRPs.

Only regular verification of PRPs is required by standard.

But I must tell that main difficulty here is : Well we accepted this point as OPRP or CCP. How shall we monitor this step in reasonable intervals? You can not monitor hands of an employee for example once-an hour. So we can monitor employees for each shift change, entrance to the production area again and again. Turnstile hand washing basins could be a good solution for minimising likelihood of hazard.

Regards.

Kara


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#15 Charles.C

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Posted 17 December 2007 - 01:52 AM

Dear Kara,

Many thks for yr example. An image speaks a thousand words, or something.
If I understand corectly, you are suggesting that an activity (call it A) of introducing a corrective action (which must also involve “frequent” monitoring) due to failure of some “general” pre-requisite type parameter such as hygiene requires that this new activity (A) is to be labelled as an oPRP.
This appears( in principle anyway) to offer the opportunity to have a very large number of oPRPs ! although many might be more correctly sub-classified as ‘temporary’ or ‘secondary’ oPRPS since they could be removed once targeted hygiene objectives were regained. (or perhaps they would become ‘primary’ oPRPs if subsequently considered to be justified [risk assessed] as a fixed activity?).

I get the feeling, but only based on seeing posted items here, that most users of i22k are not following such a rigorous adjustment procedure but maybe I’m wrong ?? Anybody ??


MONITORING is mandatory only for OPRPs and CCPs not for PRPs.

Only regular verification of PRPs is required by standard.


I seem to remember a previous thread having a (contested) opinion that the existence of “monitoring” did not allow classification of that activity as a PRP.
However I interpret yr above comment as meaning that IYO monitoring for PRPs may or may not be required / acceptable depending on the specific case.
Is there a paragraph / section in the i22k standard which states (or clarifies) the allowed degree of flexibility of this aspect ??

(I remember seeing a similar conversation in the draft standard discussion with respect to basic factory structural features being only possible as PRPs since they are not “routinely” monitored etc however someone else then said “not true’ since people “noticed” [> planned observation] every day if there were any significant holes in the roof [>control measure].)(think it was the French delegate).

(The definitions given in i22k standard are –

Monitoring – conducting a planned sequence of observations or measurements to assess whether control measures (3.7) are operating as intended.

Control measure – (food safety) action or activity that can be used to prevent or eliminate a food safety hazard (3.3) or reduce it to an acceptable level.

Verification – confirmation, through the the provision of objective evidence, that specified requirements have been fulfilled )

The nice word “can” in second definition seems to cover almost anything. in English anyway :smile: .

I am learning a lot from these inputs, many thks again. Hope other people not too bored.

Rgds / Charles.C
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Charles.C


#16 downtown

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Posted 17 December 2007 - 10:00 AM

Dear Charles,

Let us discuss importance of hand hygiene in preparation of sandwiches by hands
if you
- do a frequent monitoring
- do prompt correction in the products in case of a critical failure
- do most of the time a withdrawal or re-call (remember canteen example)

Does it matter to name this step as PRP, OPRP or CCP?
Definitions of these terms in standards and laws are not explicit enough but just giving a basic context for the term.
However, just to avoid to repeat myself I am gonna refer to the very first message in this thread. Well, It would really be better to look at the requirements of the standard than looking at these implicit definitions.

I mean if a company absolutely needs adn implements a frequent monitoring and prompt corrections/withdrawals for a nonconformity in a particular step of process, The most difficult requirements of a typical CCP/OPRP are already untertaken by it, so it is not anymore this so essental whether to put a simple O as a prefix to PRP :rolleyes:


Kind regards.

Kara


Edited by downtown, 17 December 2007 - 10:25 AM.

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#17 Charles.C

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Posted 18 December 2007 - 06:45 AM

Dear Kara,

Does it matter to name this step as PRP, OPRP or CCP?


Well, it seemingly matters to the group responsible for the concepts contained in ISO22k standard and presumably their expectation regarding its “proper’ implementation. There should have been a clear statement somewhere in the standard(s) like - "the reason for the introduction of the additional OPRPs is …..”. I presume item 7.1(b) in 22004 tries to answer this but IMO fails (particularly due to confusions as mentioned below). Personally, I am beginning to regret ever reading the standard but this is only a frustration reaction and will pass as understanding increases which it already partly has thanks to yr eloquent examples.

After re-re-reading the standard, I guess that the def.3.9, specifically the “PRP(3.8)” phrase proves yr comment that all OPRPs are PRPs :clap: :clap:

You rightly referred me back to yr excellent opening post which I apologise for having mentally stored but then forgotten, eg –

Requirement 7.10.2 suprisingly relates only to OPRPs and CCPs but not to ordinary PRPs.


And

Ordinary PRPs are not a matter of monitoring or corrections, they are only subjected to Verification by 7.8a).


I would use stronger words than “surprisingly”. If you are (universally) correct in either of the above, the word “crazy” came to my mind. I haven’t re-examined the text on this yet but I believe an option must exist so that a case-by-case situation may occur.

To offer a simple example, I think all factories which use chlorination injection systems to maintain / increase the factory process water level routinely monitor the level at least every day and define a corrective action based on an acceptable range. I doubt that anyone would not classify this as a (“sub” if you like) PRP within the overall “Hygiene’ PRP category.

If flexibility exists, it would seem simpler to simply expand an original list of sub-categories contained within a main (original) PRP category in the case that an OPRP became required. Then simply attach the mandated features (critical limits etc) and use a xref .

Time for a revised i22k ?? (1KC ?)

Regards / Charles.C
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#18 downtown

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Posted 18 December 2007 - 07:57 AM

Yes I now remember 3.9 exactly explains OPRPs are PRPs. I am happy for everything is now clear and to become aggree in this. :rolleyes:

Well, the fact 7.10.2 doesn't refer to ordinary PRPs is a little bit suprising or crazy because definition 3.14 is the same definition as in the ISO 9001 / 3.6.5 doesn't restrict it with CCPs and OPRPs. However, 7.10.2 is surprisingly does.

But practically , I as an auditor, don't mind this surprise, because we know standard PRPs are a subject of verification , scope of verification is drawn in 7.8a Verification Planning. In addition, 8.4.2 clearly indicates if verificatioon indicates nonconformity with the planned arrangements, the organisation shall take action to achieve required conformity. (Unfortunately they again prefer term action rather than corrective action.)

Kind regards.

Kara


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#19 Penard

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Posted 18 December 2007 - 09:01 PM

Dear Charles and Downtown,

To resume, I think all the differences we can have between oPRP and CCP are 'historic' differences; from the time being we are used to build a Haccp study with Codex example. This example explains differences in our minds between process critical points - CCP as cooking, refreshing..., and hygienic critical points -such as hand washing as downtown explained.

Therefore differences between both of them are not so important.

But to me, you can not require monitoring in all your process, all your steps and all your users. Even in big big factories in very developed countries, you can not forget you work with men and women, it involves you have to be careful with this people, and you have to imply them in the factory.
So your PRP's are very important : you can't monitor with cams everywhere - except from Big brother :biggrin: , you have to trust your employees, and to imply them. That's the reason why those PRP's are so important to me, because thanks to them you can rely on concrete hygienic points. I don't remember it was so clear before 22K. I can measure it with french regulation, which has immediately included it in establishment approval.

So I think we have some mistakes, some points to explain, and simplify as Charles said, but we have to keep in mind that even though some PRP can become oPRP -it always depends on your Haccp study!!-, as soon as we determine your Haccp plan, those 2 points are completely different.

This topic is very exciting, I'm very enthousiastic, thank you all, and downtown and Charles to show your passion!

Best regards,

Emmanuel.


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#20 Penard

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Posted 28 January 2008 - 12:43 PM

Just something intersting to add : I've heard a factory succeed in having 22000...without oPRP! I'll try to know more about it.

Regards,

Emmanuel.


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#21 Suzuki

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Posted 28 January 2008 - 01:20 PM

Just something intersting to add : I've heard a factory succeed in having 22000...without oPRP! I'll try to know more about it.

Hi Penard, I hope it is not true. Could this be an unaccredited certification (Non-IAF)? Interesting if you can keep us informed on this one.

Yes I now remember 3.9 exactly explains OPRPs are PRPs. I am happy for everything is now clear and to become aggree in this.

Dear Charles / Kara, I feel the standard expects us to interpret 3.9 within the context of 3.8 and in conjunction with 7.5. From the interpretation of 7.5, we should clearly define OPRPs are indeed not PRPs however they are operated to support the PRPs which are basic fundamentals in any food safety systems.

Regards
Suzuki
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#22 downtown

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Posted 29 January 2008 - 09:17 AM

well, this is not surprising. Company could manage its risks by only PRPs and CCPs. There might not have been a need for OPRP actually. Or It could have named its OPRPs as CCPs according to old and traditional nomenclature.

In some situations, company might not need even CCPs or OPRPs. Only PRPs. Why not?

Example : "Fruit and vegetable wholesalers buying from certainly trustworthy suppliers."

Kind regards.

Kara


Edited by downtown, 29 January 2008 - 09:18 AM.

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#23 Charles.C

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Posted 29 January 2008 - 09:40 AM

Dear Suzuki,

If you are saying that the text in ISO 22000 (and 22004) is both poor and highly confusing I can only agree.

From the current posts I have deduced that it is available with more clarity in non-English languages. :angry:

Rgds / Charles.C


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Kind Regards,

 

Charles.C


#24 James Chen

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Posted 31 January 2008 - 07:43 AM

This topic is absolutely a good one for understanding ISO22000. Sorry for that I haven't completed reading all these replies.But I will try best. Many thanks for all your comments here.


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chen_zhigui@msn.com.

Glad to talk about food safety with you all friends here.

#25 Penard

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Posted 28 March 2008 - 08:42 PM

Hi,

Certification I wrote about was given at the very beginning of ISO 22000; nowadays I think it wouldn' be possible.

Just to add : this factory was already ISO 9001 certified.

Regards,

Emmanuel.


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