Dear Simon / Bennii,
It's rare to hv such a detailed i22k item submitted. Takes a little time to digest.
At the minimum, many thanks and congratulations to Bennii for offering yr procedure to be commented upon. Very brave !
One really needs to see an example of the implementation to get more idea however can happily make a few comments. Anybody, please feel totally welcome to disagree with any of the following (particularly Bennii )
Some of these are (obviously) unrelated to content, only to presentation. Not trying to be nit-picking and I suspect many auditors would never hv the time to notice such things (or the interest).
One immediate comment. I don’t see the word “validation” anywhere in this document (perhaps Modarres/IFSQN is a minimum example ). Seems an important omission to me. (added1 - maybe also in ref.3.2 of procedure)
Perhaps need a bit more “Scope” – I guess the content is particularly aimed at iso22k. Nobody else uses oprp AFAIK (and I personally hope it stays that way until more articles appear to evaluate it like this one). Not sure if you intended this only to apply to the named process or to be generally usable.
Reference 3.3. I think this is not a reference.
Section 5.1. FQ10 seems to denote two different procedures.
4.1, 4.2. “Risk(hazard)” probably not a recommended naming style. See the notes in i22k section 3.3.
4.3 – “controls” is perhaps not the right word (activities??), not too sure about “generic” either.
4.4, 4.5 – Getting more to the crunch content. I interpret yr text to mean that you consider that i22k intends that none of the items in i22k section 7.2.3 are relevant to oprps ?? Do I understand correct ?? The following don't relate to yr specific process but as a random example, I noted that in this ref (cheese / heggum) –
Transportation is an oprp although it appears in i22k subsection 7.2.3 (f)
Similarly – (from surak) -
• Operational prerequisite programs that are used to control potential food safety hazards. An operational PRP is similar to a control point or CP. An example of an operational PRP is the receiving temperature of raw meat at a poultry further processing plant.
Purchased materials management seems included in i22k / 7.2.3 (f) also.
6.1.1 et al - The use of a 5x5 matrix is no problem for me in principle but the amount of numbers which are subsequently involved surely demands some validation (eg, if I was a (nasty) auditor). Compare this to say an earlier upload here from Charlorne which maybe escapes such a situation (added2 - although in truth containing some (=?) debatable choices, eg only HH > CCP? etc + [added3] also note the subsequent interpretive objections of Modarres in the same thread, ie http://www.ifsqn.com...?showtopic=3183
Not saying 5x5 wrong, just maybe bit overkill.
6.2.1, 6.2.2 Seems the arrows (<, >) are all wrong way round ?? Maybe I misunderstood.
I personally don’t “buy” this method of equal weight evaluation as I noted in Modarres’s forum thread. Willing to be convinced though, and I predict auditors will hv no problem (as per CharlesChew ?)
Many of the conceptual queries above hv been discussed before with varying conclusions (or none) so can only thank you so much for the opportunity to let people comment further.
Regards / Charles.C