A Scoring Conundrum Regarding Section 7.4.4

Dear All,

One seemingly popular methodology for categorising control measures (CMs) into either “HACCP plan (CCP) usable” or “OPRP” is to use scoring techniques to assess the various questions of section 7.4.4, paragraphs (a-g) resulting in a cumulated value for making a final decision (eg see Modarres / Bennii’s contributions on this forum). I also find this concept quite attractive but it seems, IMO, to have at least one fundamental objection which negates its acceptability for routine use. I will detail the latter in next 4 paragraphs.
(My immediate interest is with respect to microbiological hazards, eg bacterial pathogens.)

As I interpret section 7.4.4 (a-g), the standard is essentially seeking an assessment for a, to-be-evaluated CM (or combination of CMs), of it’s ability to achieve various “desired” features of a HACCP-capable CM. Inability (measured “somehow”) to attain such features results in categorisation as an OPRP. The “perfect” target features although not specifically stated are supposedly inferrable from the various elements (a-g).

Some items within (a-g) are more intelligible / less subjective / more easily assessed than others but, regardless, it seems to me that ultimately, a CM which is to be included within a HACCP plan to create a CCP (ie a critical control point) must surely, at a minimum, be capable of complying with the ISO 22000 definition of a CCP, 3.10, which states quite simply that a CCP is a “(food safety) step at which control can be applied and is essential to prevent or eliminate a food safety hazard (3.3) or reduce it to an acceptable level.” (this is effectively the Codex version I think, strictly ISO 22000 is perhaps considering this definition as "necessary but not "quite" sufficient" in its current analysis)
I interpret this definition as stating specifically (not subjectively) that if a proposed CM is, in practice, incapable of achieving the text requirements “prevent … level” then that CM cannot define a CCP within a (ISO 22000 based) HACCP plan.

Sorry about the long intro but it seemed unavoidable.

Now consider element 7.4.4 (a), I interpret this as asking whether or not the CM is capable of (i) achieving the FS objective, perhaps expressed as a Performance Objective or whatever ( ie, generally as stated by 7.4.2.3) and (ii) achieving the objective in an acceptably practical and efficient way. Expressed more simply, it is querying the CM’s capability to achieve the basic requirements of the definition 3.10 as noted above. The subsequent elements of 7.4.4(a-g) then relate to practical implementation aspects of the CM and its intrinsic robustness plus the consequences of an operational failure of the CM.

And, finally , my objection – It seems to me that the use of any alternative score to 7.4.4 (a) other than “100% capability” as expressed in def.3.10 should automatically exclude the CM as being HACCP plan capable. However the proposers of these various scoring-type plans do not appear to see any conceptual objection to cumulating a non-100% result with the additional data, eg including scores for (a) items like “not effective” , “partially effective” into the overall score. In addition, by observation, it is possible that some schemes could numerically conclude a result of “CCP” while including a response of “ineffective” to 7.4.4a.!

(A similar practical objection can be made as to the occasionally seen inclusion of “not feasible” as a possible score for the 7.4.4b (monitoring) element. Such a scenario would obviously make validation / corrective action impossible which are fundamental CM requirements to be CCP - compatible.)

If my interpretation is correct, the difficulty derives fom the fact that, for a CM to be usable in a HACCP plan, some features are not divisable into degrees of acceptability whereas others are and a suitable evaluation plan must take account of this.

As a result I am now considering to not use such scoring systems hence this post seeking user’s (or non-user's ) opinions.

Any / All Comments are welcome.

Thks and Rgds / Charles.C

Dear All,

One seemingly popular methodology for categorising control measures (CMs) into either “HACCP plan (CCP) usable” or “OPRP” is to use scoring techniques to assess the various questions of section 7.4.4, paragraphs (a-g) resulting in a cumulated value for making a final decision (eg see Modarres / Bennii’s contributions on this forum). I also find this concept quite attractive but it seems, IMO, to have at least one fundamental objection which negates its acceptability for routine use. I will detail the latter in next 4 paragraphs.
(My immediate interest is with respect to microbiological hazards, eg bacterial pathogens.)

...

As a result I am now considering to not use such scoring systems hence this post seeking user’s (or non-user's ) opinions.

Any / All Comments are welcome.

Thks and Rgds / Charles.C

Totally agree!!!

FSSM

Any other comments from those in the know?

Dear All,

One seemingly popular methodology for categorising control measures (CMs) into either “HACCP plan (CCP) usable” or “OPRP” is to use scoring techniques to assess the various questions of section 7.4.4, paragraphs (a-g) resulting in a cumulated value for making a final decision (eg see Modarres / Bennii’s contributions on this forum). I also find this concept quite attractive but it seems, IMO, to have at least one fundamental objection which negates its acceptability for routine use. I will detail the latter in next 4 paragraphs.
(My immediate interest is with respect to microbiological hazards, eg bacterial pathogens.)
As a result I am now considering to not use such scoring systems hence this post seeking user’s (or non-user's ) opinions.

Any / All Comments are welcome.

Thks and Rgds / Charles.C

Dear Charles,



I agree with your arguments. But how are we going convince CB without using the score card?



I have spent lot of time in understanding / application of the clause 7.4.4. After taking valuable inputs from this forum, I came out score card as below:



Assessment of Control Measures

Control Measures Criteria

Rating & Explanation

a. its effect on identified food safety hazards

1. Prevention

2. Reduce

3. Eliminate

b. its feasibility for monitoring

1. Auto detection & auto correction

2. Auto detection & manual correction

3. Manual detection & manual correction.

c. its place within the system relative to other control measures

1. First

2. In middle

3. Final measure

d. the likelihood of failure in the functioning of a control measure

1. Unlikely

2. Likely

3. Frequent

e. the severity of the consequence (s) in the case of failure in its functioning

1. Minor injuries

2. Major injuries / illness

3. Hospitalization / Fatal

f. whether the control measure is specifically established and applied to eliminate or significantly reduce the level of hazards(s)

1. No



3. Definitely

g. synergistic effects

1. No



3. Definitely



<br style="page-break-before: always;" clear="all"> Management of Control Measures

Total Score

oPRP Plan

HACCP Plan

7 to 14

15 to 21

After applying this score card, I felt that we have not learned anything new other than satisfying CB.



This is my humble opinion only



Thanks & Regards



V.R.