27 replies to this topic

[FSSM]

As part of my question, I would like to have feedback from ISO 22000 users:

What OPRP´s you have implemented at your facilities?

I hope some users share their experience with this issue.

Regards,

FSSM

P.S. Dear Admin. should this be moved to another topic? or is there any other place in this forum where I can read about it?

[Simon]

P.S. Dear Admin. should this be moved to another topic? or is there any other place in this forum where I can read about it?

Dear FSSM,

I think it's a great area for discussion, so I split into a new topic for you.

What OPRP´s have you implemented at your facilities?

Regards,
Simon

[FSSM]

Thank you Simon!

I think I should start sharing:

For context, our scope is Warehousing and distribution of food ingredients.

1. Pest Control
2. Chemicals Control
3. Allergens and Sensitizing Chemicals Control
4. Preventive and Corrective Manteinance
5. Foreing material Control

Yes, I know, very debatable, some of them should just be PRP´s, but we wanted to put enphasis on those, since they are the most likely sources of food safety risks during our operations.

Regards,

FSSM

[AS NUR]

Thank you Simon!

I think I should start sharing:

For context, our scope is Warehousing and distribution of food ingredients.

1. Pest Control
2. Chemicals Control
3. Allergens and Sensitizing Chemicals Control
4. Preventive and Corrective Manteinance
5. Foreing material Control

OUR PRP include :

1. Personnel Hygiene
2. GLP
3. Healthy Facility and Canteen
4. Cleaning & sanitizing Procedures
5. utility

[YongYM]

Below is the list of OPRP from my sister company:
a) Sieve for incoming ingredient e.g. flour
b) Filter for incoming potable water and cooking oil

**Edited due to typing error.

Edited by YongYM, 30 July 2009 - 07:34 AM.

[FSSM]

OUR PRP include :

1. Personnel Hygiene
2. GLP
3. Healthy Facility and Canteen
4. Cleaning & sanitizing Procedures
5. utility

Dear AS NUR, thank you, also, have you any Operative PRP´s implemented?

Regads,

FSSM

[FSSM]

Below is the list of OPRP from my sister company:
a) Sieve for incoming ingredient e.g. flour and cooking oil
b) Filter for incoming potable water

Dear YongYM,

Just to clarify, your cooking oil is also sieved?

Regards,

FSSM

[AS NUR]

Dear AS NUR, thank you, also, have you any Operative PRP´s implemented?

Regads,

FSSM

oprp in my company :

1. Strainer for liquid material
2. Sieveter for powder material
3. Filtration for water processing

Edited by AS NUR, 30 July 2009 - 01:00 AM.

[Tony-C]

I have these on my list of Operational Prerequisites and would be interested if anyone has any additional to these:

Identification and Traceability
Hygiene Management
Management of Pest Control
Control of Visitors and Contractors
Management of Cleaning
Despatch and Distribution
Maintenance
Waste Management
Hygiene Policy
Calibration
Glass Policy
Ingredients Foreign Body Control Policy
Metal Detection
Nut Handling Procedure
Control of Knives
Glass & Brittle Material Breakage Procedure
Storage
Allergen Control Procedures
Food Defence System
Control of First Aid Dressings

Regards,

Tony

[Zeeshan]

Dear Tony,

Your list has refreshed the old thread with the unresolved question: Confusion between OPRP and PRP.

http://www.ifsqn.com...t...850&hl=OPRP

In this connection, I want to ask you a question:

Whether your system has unified list of PRP and OPRP's (as given by you in your last post) or you have a separate list of PRP's.

Regards:

[Tony-C]

I have these on my list of Operational Prerequisites and would be interested if anyone has any additional to these:

Identification and Traceability
Hygiene Management
Management of Pest Control
Control of Visitors and Contractors
Management of Cleaning
Despatch and Distribution
Maintenance
Waste Management
Hygiene Policy
Calibration
Glass Policy
Ingredients Foreign Body Control Policy
Metal Detection
Nut Handling Procedure
Control of Knives
Glass & Brittle Material Breakage Procedure
Storage
Allergen Control Procedures
Food Defence System
Control of First Aid Dressings

Hi Zeeshan

Operational prp's

Regards

Tony

[Zeeshan]

Dear Tony!

Probably I could not present my question correctly.

I was asking that the list of your OPRP's contains so many programs that are generally considered as PRP's especially following:

Management of Pest Control
Waste Management
Glass Policy
Control of First Aid Dressings

If this is the list of your OPRP's then please tell me what PRP's you have?

Regards:

[Tony-C]

I was asking that the list of your OPRP's contains so many programs that are generally considered as PRP's especially following:

Management of Pest Control
Waste Management
Glass Policy
Control of First Aid Dressings

Dear Zeeshan

I see - Whether something is controlled as a prerequisite or an oprp depends on how significant the hazard is. Some people may decide pest control is an operational prp.

It is something you need to assess and decide on a site/facility/product specific basis.

I have attached a list of Prerequisite headers from my prerequisite document.

Regards,

Tony

Attached Files

•  QM_015_Prerequisite_Programmes_Headers.pdf   76.64KB   292 downloads

[FSSM]

Dear all:

Well, triying to understand how this OPRP Vs PRP thing works, is how I thought of this topic, gathering the information that you kindly posted, I have created a table where you can find a comparison of the OPRPs and PRPs we manage against PAS 220 2008.

Some questions have been raised by an auditor in a previous visit, about our decision for OPRPs, she was very specific to the fact that they should be called just PRPs because they are mentioned at 7.2.3 of ISO 22000. I totally agree with Tony-C statement, OPRPs should be selected, based on a hazard analysis, that is why in our case, we have implemented some PRPs as OPRPs. I think this argument is well based on OPRP definition (3.9)

Thank you for your help!



Regards,

FSSM

Attached Files

•  Comparison_of_OPRPs_and_PRPs_Vs_PAS220_2008.xls   25.5KB   242 downloads

[Charles.C]

Dear FSSM,

I think one part of yr problem is that the auditor is, not surprisingly, following the sequencing of the standard, ie 7.3 follows 7.2.

Also, from the auditor’s point of view, you perhaps seem to not be adhering to the basic principle of definition 3.8 (and its NOTE), particularly when semantically compared to the 3.9 definition of “operational PRP”. I may be wrong.

You may hv noticed that this standard remains quite focused on PRPs as an initial (fundamental?) setup. This is sort of parallel to the original development of “traditional” HACCP of course. I don’t think the introduction of the oprp was intended to dilute this concept, more to offer another tier within the (subsequent?) risk/hazard analysis. Based on existing comments from people who hv taken/passed the audit, I deduce the tendency is to place too much emphasis on defining the oprps and better to sort out the PRPs /haccp analysis first. I may be wrong again.

The practical conclusion is simply that it will depend on the auditor’s interpretation of the standard. Seems to me that if yr opinion differs, it is the auditor’s responsibility to clarify this separation. The suggestions in this thread illustrate the range of opinions and may all be correct to some auditors. Should be good business for consultants. (and PAS helpfully adds a bit more confusion).

I presume you passed so you must hv done something right !

Rgds / Charles.C

[Erasmo]

Dear all:

Well, triying to understand how this OPRP Vs PRP thing works, is how I thought of this topic, gathering the information that you kindly posted, I have created a table where you can find a comparison of the OPRPs and PRPs we manage against PAS 220 2008.

Some questions have been raised by an auditor in a previous visit, about our decision for OPRPs, she was very specific to the fact that they should be called just PRPs because they are mentioned at 7.2.3 of ISO 22000. I totally agree with Tony-C statement, OPRPs should be selected, based on a hazard analysis, that is why in our case, we have implemented some PRPs as OPRPs. I think this argument is well based on OPRP definition (3.9)

Thank you for your help!



Regards,

FSSM

Clasification is very important. During an audit, the best method (in my opinion) is to assess the validation of that opPRP. Some auditees think that the validation is a "more comprehensive verification" and that is not totally correct. Acceptable validations are mentioned in ISO/TS-22004 and in CAC/GL-69 (Codex). When an organization does not have a validation record, they need to assess if that control measure has to be classified as PRP. Saludos.

[Tony-C]

When an organization does not have a validation record, they need to assess if that control measure has to be classified as PRP. Saludos.

Hi Erasmo

I can understand why you say this but I can't totally agree because if you have a hazard that needs to be controlled then you may need to adjust the control measure or modify the step to validate it.

7.4.4 Selection and Assessment of Control Measures The selection and categorization shall be carried out using a logical approach that includes......whether the control measure is specifically established and applied to eliminate or significantly reduce the level of hazard(s);

8.2 Validation of Control Measure Combinations - If the result of the validation shows that ........... cannot be confirmed, the control measure and/or combinations there of shall be modified and re-assessed (see 7.4.4).

IMO you can take a very simplistic view of this:

Hazards identified = prp's
Significant Hazards identified = Oprp's
Significant hazards identified controlled at CCP's = HACCP plan

Each individual facility/product group will have to make these decisions based on their own hazard assessment.

Regards,

Tony

[FSSM]

Dear friends, thank you for your feedback!

Also, from the auditor’s point of view, you perhaps seem to not be adhering to the basic principle of definition 3.8 (and its NOTE), particularly when semantically compared to the 3.9 definition of “operational PRP”. I may be wrong.

Charles.C, well, I think the only thing that differentiates PRP from OPRP is that, OPRP is identified by the hazard analysis as essential to reduce or "eliminate" the level of a hazard. Both definitions mention an hygenic environment, so I totally agree with Tony-C point of view:

IMO you can take a very simplistic view of this:

Hazards identified = prp's
Significant Hazards identified = Oprp's
Significant hazards identified controlled at CCP's = HACCP plan

Control mesure definition (3.7) is not so good as to exclude PRPs, because a hazard can be reduced by a PRP, but it might not be essential as identified in the hazard analysis, as described for 3.9. Also, in context of other items of the standard, a control mesure is only refered to OPRPs and CCP (7.4.3 and 8.2).

When an organization does not have a validation record, they need to assess if that control measure has to be classified as PRP. Saludos.

So, as Erasmo says, OPRP should be downgraded or reclassified to PRP. Only if it is not a significant hazard. And as a PRP, a validation of it would not be required.

I think it is time to go and review our Hazard analysis to check wich OPRPs should be managed as PRP.

Regards,

FSSM

[Erasmo]

Hi everyone,
on this publication:
http://www.iso.org/i...m?refid=Ref1056

Figure 3 (decision tree) of ISO/TS-22004:2005 was modified (only a little) in order to make more understandable the re-clasification of some control measures to PRP's.

I'm going to buy it this week.

[FSSM]

Hi everyone,
on this publication:
http://www.iso.org/i...m?refid=Ref1056

Figure 3 (decision tree) of ISO/TS-22004:2005 was modified (only a little) in order to make more understandable the re-clasification of some control measures to PRP's.

I'm going to buy it this week.

Dear Erasmo:

Have you got the document?

Saludos,

FSSM

[Erasmo]

Dear Erasmo:

Have you got the document?

Saludos,

FSSM

I forgot!!!

This is the figure...

Attached Files

•  Diagram.ppt   42.5KB   218 downloads

[FSSM]

Thank you Erasmo!

It will help!

Saludos,



FSSM

[Charles.C]

Dear Erasmo / FSSM,

Thks for this attachment which i just noticed (only 2yrs late ).

Sadly, IMHO, it is no more useful than its predecessor (ie useless*).

Out of curiosity, was any "simple" method of distinguishing between OPRPs / CCPs suggested in this claimed "easier to understand" supplement ? Perhaps a direct use of the original Codex Tree with all "Not a CCP"s (barring Qu1) creating OPRPs ??

Rgds / Charles.C

* (added correction) - I should hv said almost useless. 22004's figure did highlight the location of the proposed control measure's validation step in advance of the CCP/OPRP categorisation procedure. For example, it will presumably be difficult to validate a proposed CCP if one cannot nominate objective critical limits (cf the standard's requirements for an OPRP). In fact, the aspect of "objectivity" was one of the original reasons for the introduction of OPRPs although such a lack may hinder any validation.
(I hv seen very few examples of quantitative validation of OPRPs [in the context of the standard's stated validation requirements] where they are "extended" versions of typical PRPs [although the words "in combination" in para.8.2b do offer a potential generic escape route ])
(early critiques of standard 22000 deduced that an OPRP was essentially a "lower grade" CCP, particularly due to the (intentionally?) flexible requirements of def.3.9 however 22004 attempted to reverse this viewpoint via its emphasis on "validation to acceptable safety levels". Unfortunately, IMO, the standard's interpretation of "acceptable levels" is (probably unavoidably) equally flexible so the final situation remains fluid. One might say that OPRP is a validated but unprescripted quantity.

[pices]

I have these on my list of Operational Prerequisites and would be interested if anyone has any additional to these:

Identification and Traceability
Hygiene Management
Management of Pest Control
Control of Visitors and Contractors
Management of Cleaning
Despatch and Distribution
Maintenance
Waste Management
Hygiene Policy
Calibration
Glass Policy
Ingredients Foreign Body Control Policy
Metal Detection
Nut Handling Procedure
Control of Knives
Glass & Brittle Material Breakage Procedure
Storage
Allergen Control Procedures
Food Defence System
Control of First Aid Dressings

Regards,

Tony

[Natalia86]

Dear FSSM,

I think it's a great area for discussion, so I split into a new topic for you.

What OPRP´s have you implemented at your facilities?

Regards,
Simon

We are in the fist stage of transition and analyzing the OPRP's and CCP's for the new system. Till now we realized that probably the sterilization will be an OPRP within our company (produces ingredients for dairy industry, so low pH, lactic acid bacteria's are present).

Could I ask if you use any specific tool for designation OPRP's? :)

Natalia86