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.
