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Difference between OPRP Plan and HACCP Plan?

Started by , Sep 28 2010 10:20 AM
17 Replies
Can anyone describe the difference between oPRP Plan and HACCP Plan..??? Please elaborate with the examples, if possible..
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I'm in the middle implementation ISO 22000 in primary production(chicken and hatcery farming, animal feed production, plant production etc) and have a dilema with oPRP. Should I desine oPRP for exect contaminent, for exemple Campilobacter jejuni - one oPRP, for Salmonella - second oPRP... ?

Thanks

Can anyone describe the difference between oPRP Plan and HACCP Plan..??? Please elaborate with the examples, if possible..


There is essentially no difference except the implication is that OPRP's don't have critical limits:

7.5 Establishing the operational prerequisite programmes (PRPs)
The operational PRPs shall be documented and shall include the following information for each programme:
a)food safety hazard(s) to be controlled by the programme
b)control measure(s)
c)monitoring procedures that demonstrate that the operational PRPs are implemented
d)corrections and corrective actions to be taken if monitoring shows that the operational PRPs are not in control
e)responsibilities and authorities
f)record(s) of monitoring

7.6.1 HACCP plan
The HACCP plan shall be documented and shall include the following information for each identified critical control point (CCP):
a)food safety hazard(s) to be controlled at the CCP
b)control measure(s)
c)critical limit(s)
d)monitoring procedure(s)
e)corrections and corrective action(s) to be taken if critical limits are exceeded
f)responsibilities and authorities
g)record(s) of monitoring


Regards,

Tony

I'm in the middle implementation ISO 22000 in primary production(chicken and hatcery farming, animal feed production, plant production etc) and have a dilema with oPRP. Should I desine oPRP for exect contaminent, for exemple Campilobacter jejuni - one oPRP, for Salmonella - second oPRP... ?

Thanks


You should consider all hazards and then decide if the same control measure covers several potential hazards which is often the case with pathogens.

Regards,

Tony

You should consider all hazards and then decide if the same control measure covers several potential hazards which is often the case with pathogens.

Regards,

Tony


so, oPRP per control measure in combination with contaminent/s,(of course, if the contaminent is significant)?


Tony, many thanks and regards


Jawwad thanks and regards you too

There is essentially no difference except the implication is that OPRP's don't have critical limits


Perhaps the (over?)-simplification of the year so far !!

@Jawwad, biber - if you would like to see a few comments on literature oprp / iso22000 vis-a-vis primary production of vegetables, can try this post -

http://www.ifsqn.com...dpost__p__36566
(see especially doc1, iii [from memory])

Rgds / Charles.C

There is essentially no difference except the implication is that OPRP's don't have critical limits:



Regards,

Tony



So are you saying that the oPRP's are the same as the PRP's? I was thinking that the PRP's are your GMP program, Pest Control plan, Sanitation program, etc. This has completely confused a lot of FS team members trying to get ISO certification....

So are you saying that the oPRP's are the same as the PRP's? I was thinking that the PRP's are your GMP program, Pest Control plan, Sanitation program, etc. This has completely confused a lot of FS team members trying to get ISO certification....


Dear Carol
Welcome to the forum

Please do not take my posts out of context again

To correct you PRP's aren't mentioned it was a question regarding OPRP's and CCP's

Jawwad, on 28 September 2010 - 11:20 AM, said: Can anyone describe the difference between oPRP Plan and HACCP Plan..??? Please elaborate with the examples, if possible..


There is essentially no difference except the implication is that OPRP's don't have critical limits:
7.5 Establishing the operational prerequisite programmes (PRPs)
The operational PRPs shall be documented and shall include the following information for each programme:
a)food safety hazard(s) to be controlled by the programme
b)control measure(s)
c)monitoring procedures that demonstrate that the operational PRPs are implemented
d)corrections and corrective actions to be taken if monitoring shows that the operational PRPs are not in control
e)responsibilities and authorities
f)record(s) of monitoring

7.6.1 HACCP plan
The HACCP plan shall be documented and shall include the following information for each identified critical control point (CCP):
a)food safety hazard(s) to be controlled at the CCP
b)control measure(s)
c)critical limit(s)
d)monitoring procedure(s)
e)corrections and corrective action(s) to be taken if critical limits are exceeded
f)responsibilities and authorities
g)record(s) of monitoring


I am surprised and really pleased that by implication so many FS Team members are visiting our forums and reading my posts

If any FS Team members are confused or need some help or advice then I will be very happy to assist them, simply PM me or e-mail me.

Regards,

Tony


Jawwad, on 28 September 2010 - 11:20 PM, said:

Can anyone describe the difference between oPRP Plan and HACCP Plan..??? Please elaborate with the examples, if possible..


Hi Jawwad,

We have categorized any control measure , that controls a significant hazard, as an oPRP, if the Control measure was not part of the process flow or was part of an PRP.

Regards,

Sriram
Dear Sriram,

Thank you very much for yr input and welcome to the Forum ! .

if the Control measure was not part of the process flow


I appreciate you are attempting to simplify the choice of OPRPs however you will find various examples in the literature which seem to disagree with yr logic unless you have an extremely wide interpretation of PRP . Additionally, yr assumption / restriction appears not in accordance with ISO 22004, para.7.4.4 ?

Nonetheless, I do agree that the ISO 22000/04 standards are highly ambiguous as to exactly how they should be interpreted; particularly inasmuch as 22004 seems to imply that any mixture of CCPs/OPRPs is ultimately acceptable since adequately implemented validation will always ensure the desired safety result!. Q.E.D.

I am curious if yr methodology was readily acceptable to the auditor. If you wish to post any examples of the usage, I am sure they would also be very interesting to the general forum.

Rgds / Charles.C

@Jawwad - did you find the link I previously posted any help ? Comments are always welcome, (+) or (-)

So are you saying that the oPRP's are the same as the PRP's? I was thinking that the PRP's are your GMP program, Pest Control plan, Sanitation program, etc. This has completely confused a lot of FS team members trying to get ISO certification....


Although this question is out of context but to clear the situation, I can not hold my self to intervene.

As per ISO 22000:2005 definition 3.9: Operational prerequisite programmes are PRPs' that are identified by the hazard analysis as essential in order to control the likelihood of introducing food safety hazards to and/or the contamination or proliferation of food safety hazards in the product(s) or in the processing environment

IMO, OPRPs' are those PRPs' which are assessed as essential control measures to control hazards that are identified after hazard analysis. Its difficult or sometimes impossible to set critical limits for PRPs' for example it is difficults to set criterion for acceptability of results of implementation of pest control activities and personal hygiene. People may have set their own criterion for acceptability but it would be debatable for others. It means for control measures used during operations for which you can justify "No critical limits", you can treat or categorize them as OPRPs'.

I know the efforts of authors of ISO 22000 and many auditors are in line with "over-complication", IMHO, if your auditor is a "good man/lady" he/she should accept a simple approach like what I like: Control Measures = GMPs' (=PRPs'+OPRPs') + CCPs'.

Comments welcome!

Regards:
M.Zeeshan.

Its difficult or sometimes impossible to set critical limits for PRPs' for example it is difficults to set criterion for acceptability of results of implementation of pest control activities and personal hygiene. People may have set their own criterion for acceptability but it would be debatable for others. It means for control measures used during operations for which you can justify "No critical limits", you can treat or categorize them as OPRPs'.


Zeeshan, right in the target


It's not just difficults to set criteria for oPRPs, also their validation(8.2) is hige problem.
How is it possible pass validation( 8.2) of some control measure if there no established limit, for exemple present of specific pest in enviroment? There is no logic at all.
I have simple approach: if I can't establish limit (or the legislation haven't set the limit) for specific contaminent, that control mesuars (which are set by low or CAC as GHP or GMP) are PRP. So, I think everyone should be very careful when does risk analizes and determination PRP/ oPRP/CCP.

Best regards
Biber (pepper)

@Jawwad, biber - if you would like to see a few comments on literature oprp / iso22000 vis-a-vis primary production of vegetables, can try this post -

http://www.ifsqn.com...dpost__p__36566
(see especially doc1, iii [from memory])

Rgds / Charles.C


Thanks Charls.C and best regards
Biber

Dear Sriram,


I appreciate you are attempting to simplify the choice of OPRPs however you will find various examples in the literature which seem to disagree with yr logic unless you have an extremely wide interpretation of PRP . Additionally, yr assumption / restriction appears not in accordance with ISO 22004, para.7.4.4 ?

Nonetheless, I do agree that the ISO 22000/04 standards are highly ambiguous as to exactly how they should be interpreted; particularly inasmuch as 22004 seems to imply that any mixture of CCPs/OPRPs is ultimately acceptable since adequately implemented validation will always ensure the desired safety result!. Q.E.D.

I am curious if yr methodology was readily acceptable to the auditor. If you wish to post any examples of the usage, I am sure they would also be very interesting to the general forum.




Dear Charles,

Apologies for not replying earlier, but as a newbie then I was not logging in often, plus work network did not allow forums initially.

In any case, the delay helped me work with ISO22000 in more detail, and Yup.. you were right in all your comments. I have now realized that it is easier to look at FS as a complex decision process and realize every plant, process product needs its own unique analysis. A CCP here may become an oPRP in another plant etc...

I look at the tools now, to id the hazards and then if I am lucky enough to have a control measure then I go through all the sub clauses in 7.4 to determine the categorization.

As you can see, I am now much more wary of generalizations and second guessing the standard!

The best part of ISO22000 and oPRP is that I have now been able to id 'non value adding ' steps which were put in based on ' good to have' feelings... i.e. controls which do not synergise with any further controls, are redundant in their lethality/mitigation and in fact their removal has no impact on FS. Needless to say, I have also id many controls which are ultimately not effective, despite what we have noted in the plan, and that knowledge itself has become a catalyst for improvement projects.



Cheers,

SriramB

The best part of ISO22000 and oPRP is that I have now been able to id 'non value adding ' steps which were put in based on ' good to have' feelings... i.e. controls which do not synergise with any further controls, are redundant in their lethality/mitigation and in fact their removal has no impact on FS. Needless to say, I have also id many controls which are ultimately not effective, despite what we have noted in the plan, and that knowledge itself has become a catalyst for improvement projects.

Cheers,

SriramB


Sounds good, can you give examples?

Regards,

Tony

Sounds good, can you give examples?

Regards,

Tony



Hi Tony,

A key info to note, is that, as a Team when we reviewed the HACCP we had individual opinions about the effectiveness of any particular control either on its own or as a part of a set of controls addresssing a particular hazard. So a 'non value adding control' is not something you always get unanimous agreement to . Plus, I readily acknowledge that this was a consequence of a general HACCP review , rather than a focussed approach to find redundant controls.

But for an e.g.:

1.
In the water treatment area, there was a carbon filter which was used to strip the water of Chlorine post chlorination. (chlorination used as sterilant). Due to changes in the system some time back, the water is no longer chlorinated by council and we had moved to other sterilsation techniques. But the Carbon filter remained in the process ( as it has potential to remove other taints etc..). ( We could find no history of taints incoming, and on audit of the hydraulics find the probability very low.)

Now in the review ,you find the carbon can actually add more of a micro risk (if not maintained) and is no longer required for the purpose envisaged in the original design.

2.
On the other hand, one of the lines has got containers coming in and being depalled oto the line manually (Operator placing on conveyor). Ideally, one would have a rinser to clean out physical contaminants from the containers, but in this case the line was such that there is no place for a Rinser.

The HACCP team had identified the 'Operator" as the control measure (provided with training, visual aids etc), to inspect the containers during the process of depalling and ensuring that physical contaminants (of Visible size) are absent. As a consequence the 'operator' becomes the CCP.

When we reviewed the HACCP again in later years, we find that the operator ( not witstanding skills and zeal) could not gaurantee the requirements of 7.4.4 and we had no option but to classify the hazard as one which was 'Uncontrolled". We presented this to Mgt, highlighting potential consequences and got documented plans for moving the line to a different site.

Apologies if the e.g are vague, as the process also rapidly got modernized subsequent to the reviews which made some of the suggestions redundant, but I raised this point to highlight that as FS managers we can contribute to bottomlines as well as reduce risks.

Cheers,

SriramB

Hi Tony,

On the other hand, one of the lines has got containers coming in and being depalled oto the line manually (Operator placing on conveyor). Ideally, one would have a rinser to clean out physical contaminants from the containers, but in this case the line was such that there is no place for a Rinser.

The HACCP team had identified the 'Operator" as the control measure (provided with training, visual aids etc), to inspect the containers during the process of depalling and ensuring that physical contaminants (of Visible size) are absent. As a consequence the 'operator' becomes the CCP.

When we reviewed the HACCP again in later years, we find that the operator ( not witstanding skills and zeal) could not gaurantee the requirements of 7.4.4 and we had no option but to classify the hazard as one which was 'Uncontrolled". We presented this to Mgt, highlighting potential consequences and got documented plans for moving the line to a different site.

Cheers,

SriramB


Sensible decision and I agree with the "Uncontrolled" decision. I usually see inversion as a minimum.

Regards,

Tony
1 Thank
Hi!

Define OPRP in ISO 22000 only. EX: It may be the last filter in process, or allergen information.

Pls see attached file can applying?

Regards,
Dinh

Attached Files


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