Critical Process Step

We are a French film producer, recently BRC/IoP certified and up to welcome the second audit.
We move to the New Standard and observe they imagined a new requirement :
Identify those steps which arer critical to the process.
How do you manage that ?
On my opinion, there is no link between a CCP and a CPS but, finally, not so sure.

Printing those steps in block letters on the flow chart : is it enough to identify the steps or do we have to justify ?

Thanks for your hepl and congratulations to Simon for this great forum.

Hello kerguilloten, welcome to the forums and congratulations on your first post.

The developers of the BRC Packaging Standard are frightened of mentioning HACCP and HACCP terminology for some reason, I think because they believe that packaging companies are frightened of HACCP - we were in 1992.

CPS is mentioned a couple of times in Section 3 Hazard and Risk Management System. I think the meaning of CPS is the same as CCP. And of course the BRC/IOP's Hazard Analysis is for all intents and purposes the same as HACCP.

Regards,
Simon

Is there difference between a CCP and a CPS?

We gave a thought and it is still under discussion.
We could regard them as different when the following line of arguments is followed.
CCP: this is a control point that is part of the input of a process.
Example: the sterilisation process of canned food. Input here is the temperature of the sterilisation process, as long as the temperature is within the control boundaries the output can be regarded as OK.
CPS: this a step in a process were you control on the output.
Example: production of PET bottles, every PET bottle is inspected on faults by a camera after it is blown. Despite all extrusion parameters are in control you have to check on irregularities as the process is very dynamic.

Remember to share good fortune with your friends, Okido

I may be wrong Okido but in my opinion I think you are overcomplicating it. Here is the definition of CCP from Codex Alimentarius:

Critical Control Point (CCP) - A step in the process at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.

Therefore at a Critical Process Step you need to apply control.

I told you the BRC liked to confuse.

Anyone else care to comment?

Regards,
Simon

Hello guys,

My comments.

Not my usual area of involvement but Section 3 clearly mentions the need to determine and identify CPS from the process flow which is based on the decision tree model as laid out in the BRC-IOP Standard.

Therefore, all identified CPS(s) are steps that are critical to the production of safe products AND a loss of control on any of the determined CPS would result in a compromise of product safety.

Consequently, the importance of Sections 5,6 and 7 are highlighted as potential elements that require prerequisite procedures for controls over CP(s) while specific monitoring steps are designed for CPS(s).

In essense, end product output control or testing is not the objective but rather in-process controls of CPS is paramount.

Charles Chew

Therefore, all identified CPS(s) are steps that are critical to the production of safe products AND a loss of control on any of the determined CPS would result in a compromise of product safety.

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Hi Charles,

So do you agree with me that CPS in BRC/IOP can be considered the same as CCP?

Regards,
Simon

So do you agree with me that CPS in BRC/IOP can be considered the same as CCP?

If adequately and accurately determined in accordance with the BRC-IOP decision tree structure and where the qualitative and quantitative risk assessments indicate potential significant safety compromise if loss of control were to occur - Yes!

Charles Chew

We are a French film producer, recently BRC/IoP certified and up to welcome the second audit.
We move to the New Standard and observe they imagined a new requirement :
Identify those steps which arer critical to the process.
How do you manage that ?
On my opinion, there is no link between a CCP and a CPS but, finally, not so sure.

Printing those steps in block letters on the flow chart : is it enough to identify the steps or do we have to justify ?

Thanks for your hepl and congratulations to Simon for this great forum.

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Hi all

I think it is wise to read the Codex Alimentarius texts regarding the HACCP-technique. This will clarify a lot.
Go to the links page on www.foodfocus.nl and download these texts.

Regards

Jan Verhoeven