58 replies to this topic

[vasman]

Dear Members,

I found out that ISO just published a Technical Standard, the ISO/TS 22002-1:2009 with title "Prerequisite programmes on food safety -- Part 1: Food manufacturing".

http://www.iso.org/i...?csnumber=44001

It ...specifies requirements for establishing, implementing and maintaining prerequisite programmes (PRP) to assist in controlling food safety hazards.

It ...is neither designed nor intended for use in other parts of the food supply chain.

I guess it is something like BSI PAS 220:2008. I haven't bought it yet but I believe it may be a copy of it.

I am food safety consultant in Greece (our offices are in Athens).

When I get more information about the way it will be applied in food industries, I will let you know (especially about certification bodies).

[Charles.C]

Dear vasman,

Thks for this interesting information and Welcome to the forum

Would be even more interesting if they issued some worked - out examples for Oprps ??!! Or perhaps a usable "Tree" ? Hopefully the Secretariat read this forum.

Rgds / Charles.C

[vasman]

Hello Charles.C

I agree with you. Our permanent problem during implementation of a FSMS is to deside whether a hazard is CCP or OPRP.

The result if you ask 10 people will be 10 different aspects.

I hope someday someone somewere will make a new decision tree commonly accepted.

VasMan

[Simon]

Thank you for the information Vasman.

Members how does this affect PAS 220 and FSSC 22000? If at all.

Regards,
Simon

[infoiqc]

I beleive that ISO/ TS 22001-1 will replace PAS 220:2008.

Happy holidays,
Gail
IQC
Israel

[Simon]

I beleive that ISO/ TS 22001-1 will replace PAS 220:2008.

Happy holidays,
Gail
IQC
Israel

Hi Gail,

Taking it a step further.

So FSSC 22000 Certification will become ISO 22000 + PAS 220 ISO/ TS 22001-1

Or will ISO 22000 + ISO/ TS 22001-1 become Certification to ISO 22000 for Manufacturing.

Regards,
Simon

[Ken]

I've had a chance to read the standard and it is based on BS PAS 220:2008. I think this must the start of a series which specifies pre-requesites for different sectors of the food industry to expand 7.2.3 of ISO 22000. If so we can expect to see more over time (anyone know of others under development?).

This ISO 22002 standard covers the following:

Construction & Layout of buildings
Layout of premises and workspace
Utilities - air, water and maintenance
Waste disposal
Equipment suitability, cleaning and maintenance
Management of purchased materials
Measures for prevention of cross contamination
Cleaning and sanitising
Pest control
Personal hygiene and employee facilities
Rework
Product recall procedures
Warehousing
Product information / consumer awareness
Food defence, biovigilence and bioterrorism (in simple terms security of the establishment)

The standard fills the gaping whole in ISO 22000 under 7.2.3 if we accept the usual interpretation that pre-requesites are the requirements which must be in place before implementing haccp so invaluable for anyone implementing ISO 22000. It is already available as a download on the ISO website.

The Scope seems to be clear that ISO 22002 should be used by food manufacturers implementing PRP's as a part of a ISO 22000 management system and that exclusions from the requirements of ISO 22002 must be justified by hazard analysis and must not affect their ability to meet the requirements of ISO 22000.

Logic dictates that ISO 22002 must be taken into consideration by auditors when auditing a food manufacturer (Yes I know that I put the words logic and ISO in the same sentence but can any ISO auditors out there confirm this to be the case?)

Regards

Ken

[Simon]

I've had a chance to read the standard and it is based on BS PAS 220:2008. I think this must the start of a series which specifies pre-requesites for different sectors of the food industry to expand 7.2.3 of ISO 22000. If so we can expect to see more over time (anyone know of others under development?).

This ISO 22002 standard covers the following:

Construction & Layout of buildings
Layout of premises and workspace
Utilities - air, water and maintenance
Waste disposal
Equipment suitability, cleaning and maintenance
Management of purchased materials
Measures for prevention of cross contamination
Cleaning and sanitising
Pest control
Personal hygiene and employee facilities
Rework
Product recall procedures
Warehousing
Product information / consumer awareness
Food defence, biovigilence and bioterrorism (in simple terms security of the establishment)

The standard fills the gaping whole in ISO 22000 under 7.2.3 if we accept the usual interpretation that pre-requesites are the requirements which must be in place before implementing haccp so invaluable for anyone implementing ISO 22000. It is already available as a download on the ISO website.

The Scope seems to be clear that ISO 22002 should be used by food manufacturers implementing PRP's as a part of a ISO 22000 management system and that exclusions from the requirements of ISO 22002 must be justified by hazard analysis and must not affect their ability to meet the requirements of ISO 22000.

Logic dictates that ISO 22002 must be taken into consideration by auditors when auditing a food manufacturer (Yes I know that I put the words logic and ISO in the same sentence but can any ISO auditors out there confirm this to be the case?)

Regards

Ken

Hi Ken, and thanks for that. I cannot add any facts, but I am interested to discover what other guidelines are planned, for example packaging, food service.

Also I would like to know whether this renders PAS220 obsolete and whether FSSC 22000 will be using ISO/TS 22002-1:2009, PAS 220 or both / either. As well as whether this release has any impact (positive/negative) on FSSC 22000 itself.

Regards,
Simon

[Ken]

Simon

I cannot answer most of your questions but can tell you that ISO 22002 contains exactly the same wording as PAS 220 except the words 'ISO 22000' are substituted for 'PAS 220' where relevant in the text. There is also a 'Foreword' to put the standard in context.

My interpretation is that the status of PAS 220 has been elevated from a British standard to an International standard. ISO 22002 would need to be taken into consideration by auditors when auditing a manufacturing environment.

It would interesting to see if ISO 22000 is recognised by GFSI at least for manufacturing - Someone else on the forum might be in a better position to speculate on this.

The ISO website states the following:

'Technical specifications shall be reviewed at least every three years to decide either to confirm the technical specification for a further three years, revise the technical specification, process it further to become an International Standard or withdraw the technical specification.

After six years, a technical specification shall be either converted into an International Standard or withdrawn'.

We should get more information as people return to work.

Regards

Ken

[vasman]

Dear Members

First off all, I would like to wish you a healthy and safe 2010.

During a conversation a had with a lead auditor of a certification body, he told me that they might give a paper (something like certificate) of meeting the requirements of ISO/TS 22002-1 with the certificate of ISO 22000:2005.

Of course only to food manufactures and only to them who have established preventive measures for prerequisite programs as they are in ISO 22002.

It may replace PAS 220. Who knows the luck of FSSC 22000? Maybe it won't be useful anymore.

Vasman

[Simon]

Simon

I cannot answer most of your questions but can tell you that ISO 22002 contains exactly the same wording as PAS 220 except the words 'ISO 22000' are substituted for 'PAS 220' where relevant in the text. There is also a 'Foreword' to put the standard in context.

My interpretation is that the status of PAS 220 has been elevated from a British standard to an International standard. ISO 22002 would need to be taken into consideration by auditors when auditing a manufacturing environment.

It would interesting to see if ISO 22000 is recognised by GFSI at least for manufacturing - Someone else on the forum might be in a better position to speculate on this.

I've not got a copy but that is exactly what I've been told – ah well more standards to buy.

Yes that's just my question has this jumped FSSC 22000 or will FSSC 22000 just use the new guidelines. I think the FSSC Certification scheme is owned by the people behind the Dutch HACCP scheme although I could be wrong.

Is it sinister, jockeying for positions by Certification Bodies or nothing more sinister than a British Standard being elevated to an International one? More questions than answers here I’m afraid.

Ah well a nice bit of intrigue to spice up the New Year.

Regards,
Simon

[Ken]

Is it sinister, jockeying for positions by Certification Bodies or nothing more sinister than a British Standard being elevated to an International one? More questions than answers here I’m afraid.

Ah well a nice bit of intrigue to spice up the New Year.

Regards,
Simon

Simon

We are all cynics - ISO 22000 was and still is an incomplete and confusing standard which in my view complicates Haccp. (Lots of chat on the forum already on this topic!) BSi had the foresight to fill the gap realising that you cannot have an effective haccp system unless it is built on suitable pre-requesties so credit to them.

I don't think that ISO had any choice but to fill the gap and used PAS 220 which had already been developed and had gained some credibility. I view this as a positive step which can only help the credibility and wider acceptance of ISO 22000. (at least in manufacturing).

Ken

[Simon]

Simon

We are all cynics - ISO 22000 was and still is an incomplete and confusing standard which in my view complicates Haccp. (Lots of chat on the forum already on this topic!) BSi had the foresight to fill the gap realising that you cannot have an effective haccp system unless it is built on suitable pre-requesties so credit to them.

I don't think that ISO had any choice but to fill the gap and used PAS 220 which had already been developed and had gained some credibility. I view this as a positive step which can only help the credibility and wider acceptance of ISO 22000. (at least in manufacturing).

Ken

I'm all for that Ken, but it's 'confusion' what keeps this place alive.

If you find anything else out let us know and I will do likewise.

Regards,
Simon

[Tony-C]

I have been in touch with BSI and they have said they will make a decision as to whether PAS 220 will be withdrawn in the light of ISO 22002 by the end of January.

Regards,

Tony

[Charles.C]

Dear All,

Must say that I find all this manouevring rather strange, albeit amusing from a non-users viewpoint.

If the basic current objective of ISO is to retain their 100% lock on an alternative auditable standard to the Famous 4, why didn’t they simply update the 22000 document where there is a nice list of prerequisites already offered?.
Furthermore, I don’t see how any standard can offer a totally prescribed list for prerequisites since HACCP by definition relates to the user’s specific situation. This also applies to BRC etc equally IMO since they require the HACCP component to comply with the Codex guidelines. Personally I never had any fundamental objection to the existing list in 22000, my distaste related to the surrounding text which was supposed to explain their application!.

Rgds / Charles.C

[Ken]

Charles

The reason for not updating ISO 22000 is that PRP's will differ from one sector of the food industry to another. This may be the first of a series of Technical Standards for different sectors of the food industry. The ISO 22000 core is common to all sectors and the Technical Standards for PRP's would be sector specific and expand on section 7.2.3 of ISO 22000. On the face of it, it appears to be a logical approach.

My information from another source is as follows:

'At the first meeting of the new subcommittee charged with responsibility for the ISO 22000 family (ISO/TC34 SC17) in September 2009, there was an extensive discussion of this approach' (i.e Technical Standards for sector specific PRP's)

[See http://www.iso.org/i...l?commid=583916 for information about the committee.]

'As a result, work is on going in SC17 to clearly define two internal procedures. One will deal with requirements for developing PRP TS's or transforming relevant documents from interested parties into a TS.

The second procedure will more fully define concept and expectations for externally developed control measures. The later are an option identified in ISO 22000 for small and medium sized enterprise to use in place of a full site specific hazard analysis'.

I'm told that work is ongoing but they are not due to meet again until October 2010.

As usual, one answer and lots more questions!

[Charles.C]

Dear Ken,

I appreciate yr amplifications (and yr previous posts). I am unsure as to the rationale behind ISO’s innovations, whether (nobly / purely) user-oriented or simply protecting their business model. I suppose it has to be both.

I note that the list of 22002 in yr previous post is effectively identical to the total ordered content of 22000/7.2.3 all the way to item (j). So I presume the last 5 categories were considered to be the critically missing specific chunks for “pure” food manufacturers, namely –

Rework
Product recall procedures
Warehousing
Product information / consumer awareness
Food defence, biovigilence and bioterrorism (in simple terms security of the establishment)

Warehousing seems an acceptable infrastructure 22000 addition to me. The others are a real mix. The first two admittedly don't directly fit into the 22000/3.8 definition. Not sure exactly what the 4th means and as for the 5th, clearly important these days but ......

Out of curiosity, how long is ISO 22002, 1 page ?

added - after a rethink, I suppose one of the fundamental difficulties in achieving a GFSI compatible version of iso 22000 is simply that the original formulation of PRPs in ISO 22000 via def.3.8 is fundamentally not really compatible with the typical GFSI options as derived from the many existing prerequisites based on "interpretations" of HACCP. For example, it seems rather impossible IMO to comfortably equate the last item in above list with maintaining a hygienic environment in the sense of 3.8 . (or even with respect to Codex ? ) As a result, the PRP axioms of iso 22000 are perhaps being unavoidably compromised by 22002 and forthcoming successors. If such is not a problem then I guess all options are open.

Rgds / Charles.C

[Simon]

ISO 9001 provides broad requirements for a management system; ISO 9004 provides some interpretation of the requirements of ISO 9001 in ‘plainer’ English as well as useful guidance on how to meet the requirements. If ISO 9001 (and its smarter more useful buddy) were food safety management system documents, the pair would not be nearly prescriptive enough to satisfy the GFSI benchmark test.

ISO 22000 is like ISO 9001 insomuch as it provides broad requirements. These requirements are way too vague for GFSI and so ISO/TS 22002-1:2009 adds the meat to the bones. On its own ISO 22000 is next to useless – for a food safety certification standard.

Regards,
Simon

[Tony-C]

Dear Ken,

Warehousing seems an acceptable infrastructure 22000 addition to me. The others are a real mix. The first two admittedly don't directly fit into the 22000/3.8 definition. Not sure exactly what the 4th means and as for the 5th, clearly important these days but ......

Out of curiosity, how long is ISO 22002, 1 page ?

added - after a rethink, I suppose one of the fundamental difficulties in achieving a GFSI
Rgds / Charles.C

Hi Charles

Product Information includes storage, preparation and serving instructions applicable to the product which will need to be understood by the consumer in order for some products to be safe when consumed.

The standard is 26 pages long.

Kind regards,

Tony

[Charles.C]

Dear Tony,

Thks for info. Encyclopaedia 22000ica in the making.

I find it rather curious that the 22000 requirement for defining oprps is seemingly not out of compatibility with GFSI’s Codex. It would perhaps be useful if BRC et al added this feature so that a further set of ISO standards could be generated. Vol 3 to complete the century.

@Simon -

These requirements are way too vague for GFSI and so ISO/TS 22002-1:2009 adds the meat to the bones.

If 22002 contains practical, clear, examples to illustrate the PRP list then I agree with you. However knowing ISO, I fear that this may well not be the case. Equally, if items like the insertion of requests for (totally undefined) “risk analyses” seemingly at will in BRC are representative of GFSI “meat”, then I also foresee a gloomy future for this unifying attempt. Of course, like documentation, if one has the funds for a “risk assessment” "section" then everybody is happy.

Rgds / Charles.C

[Mugur]

Hi Ken, and thanks for that. I cannot add any facts, but I am interested to discover what other guidelines are planned, for example packaging, food service.

Also I would like to know whether this renders PAS220 obsolete and whether FSSC 22000 will be using ISO/TS 22002-1:2009, PAS 220 or both / either. As well as whether this release has any impact (positive/negative) on FSSC 22000 itself.

Regards,
Simon

ISO/TS 22001-1 is basically the new name for the PAS 220, anywhere were PAS 220 is mentioned also ISO/TS 22001-1 may be read.

[Simon]

ISO/TS 22001-1 is basically the new name for the PAS 220, anywhere were PAS 220 is mentioned also ISO/TS 22001-1 may be read.

Thanks Mugur. I think that's just about what we had all heard and concluded.

Does anyone know how that works then. Do BSI and ISO share the cash from sales? I guess so.

There's good money in standards.

[Ken]

Dear Tony,

If 22002 contains practical, clear, examples to illustrate the PRP list then I agree with you. However knowing ISO, I fear that this may well not be the case.

Rgds / Charles.C

Charles

I think Tony & Simon have already answered some of your questions from an earlier post of mine - thanks for that, couldn't have put it better myself.

To pick up another of your points, the standards within food manufacturing are so diverse and it is difficult to give clear examples even when the same prp's apply. For example the fabrication standards in a bakery will be different to a primary fish processing factory which again will be different to a high risk chilled food company.

Certainly in the UK we think we know where to 'pitch' the standards as we have a long history of supplier audits and third party certification. The problem we have is that in the pursuit of perfection, standards can be 'higher' than is actually needed for effective food safety so this can cloud our judgement when trying to assess the suitability of a factory which is not subject to the same external pressures.

It must be difficult for some companies and even more difficult for ISO 22000 auditors with limited exposure to the food industry to assess the suitability of PRP's (subject of another thread I think!).

I don't think you can successfully implement or audit ISO 22000 unless you have a thorough understanding of the technology behind food production, practical experience in the food industry and a thorough knowledge of Haccp. (Oh and knowledge of ISO 22000 of course)

On the subject of oPRP's this was something dreamed up by ISO and has been covered extensively elsewhere. Having lived with the idea for a while it does sort of make sense now, but not in the way in which ISO have suggested.

[vasman]

Members,

I don't know when this ''war'' between manufacturers and retailers will end. I suppose never. Manufacturers are in the middle (producers and retailers) and retailers have the pressure from consumers because of the hundrends of complaints.

This war born PAS 220 and now ISO 22002-1.

I have some new information that retailers prepare a new PAS for prerequisite programmes for retail (and maybe the ISO 22002-2.

If evereything ends to ISO, I think it will be for good becaude this way we will have something, let's say, independent.

[Charles.C]

Dear Ken,

Thks for the comments. I deduce that you consider the 22002-1 standard a worthwhile document despite yr diversity caveats. Time will tell I suppose. It does seem remarkable to me that ISO which has been synonymous with generic quality standards has now become so malleable. Interesting times.

Rgds / Charles.C