7 replies to this topic

[Clemkonan]

Is a decision tree approach used to identify operational PRP's as is done for CCP's and if so can someone share an example I was thinking that there must be a logical way of doing this so that a clear and effective identification and separation of CCP's and OPRP's emerges and by difference what remains are PRP's.

Similarly, whereas critical limits are then assignable for CCP's , monitoring limits would be assignable for OPRP's and both would have correction, corrective action and verification requirements.

So by way of example my product is chocolate , a screen is being used to control metallic FM, the rationale for calling it an OPRP is what?, the monitoring limit or requirement is what?, if there is failure at this step , the correction step is what?, etc.

I am thinking that for the auditor or assessor coming in checkout the facility summary tables would exist showing the derivation of each CCP and OPRP respectively.

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

[Charles.C]

Dear Clemkonan,

Welcome to the forum ! (2 yrs back!)

No problem at all but you might usefully try a little searching here for OPRP

The short answer is that a variety of opinions exist on yr questions, particularly due to the ambiguity / subjectivity in the standards iso 22000 / 22004 etc. Bit like HACCP but even more so.

As a starter, this thread contains a review of many of the primary thoughts here on yr questions although there are, probably, hundreds of others, some longer, some shorter -

http://www.ifsqn.com...dpost__p__34239

Some worked examples (but not chocolate) are presented in posts 27,32 of above thread however there are both shorter / longer ones accessible here. I don't think anybody here has posted examples which were specifically auditor-unacceptable.

As far as general auditor-acceptability goes, there are a variety of opinions existing here on what is the most pragmatic response but since I'm not currently using the standard, i will defer that aspect to other people. From some of the posts here I deduce that there can be significant difference between auditors as to what level of detail is expected but this is only a feeling. (I have experienced analogous situations with traditional HACCP / BRC audits.)

Rgds / Charles.C

PS - the current, shortest, suggested general procedure here is probably due to TonyC -

I prefer to use the following rules:

Non Significant Hazards Identified - Controlled by PRPs
Significant Hazards that are not CCPs - Controlled by Operational PRPs
Hazards at CCPs - Controlled by HACCP plan

If you apply these rules then you can use a standard decision tree.

( http://www.ifsqn.com...dpost__p__32013 )

However you might find the subsequent comments of interest also.

[Charles Chew]

Is a decision tree approach used to identify operational PRP's as is done for CCP's and if so can someone share an example I was thinking that there must be a logical way of doing this so that a clear and effective identification and separation of CCP's and OPRP's emerges and by difference what remains are PRP's.

Similarly, whereas critical limits are then assignable for CCP's , monitoring limits would be assignable for OPRP's and both would have correction, corrective action and verification requirements.

So by way of example my product is chocolate , a screen is being used to control metallic FM, the rationale for calling it an OPRP is what?, the monitoring limit or requirement is what?, if there is failure at this step , the correction step is what?, etc.

Hi,
You are right about every thing you have written. In summary, you have control measures under the "3-leg structure" that basically manages the entire FSMS.

# CCPs and OPRPs are data implementation programmes - which means you have to record monitoring data which are benchmarked against their respective CL and ML. On this note, determining CCP or OPRP is done using the same hazard analysis matrix which you will need to justify why the specific process point is a CCP or OPRP. (its quite simple really)

# PRPs are basic infrastructures and maintenances needed to ensure environment is suitable for the production of safe food. PRPs may come in the form of procedures, policies, instructions etc designed to support infra and maintenances programmes. No data needed but system validation and verification needed through various data analysis to support MR for improvement purposes.

Over the last 5 years since ISO22000 was released, it surprises me why ppl remain confused over these terms. ISO TC had done a good job on ISO22000 however FSSC through PAS 220 merely explains the term PRP further which is really not necessary but was IMO, PAS 220 was designed to be explicit to meet the UK Food Law requirements for GFSI acceptance. I hope this explanation and the attachment helps clear the ambiguity!

Attachment file is too big to upload - refer to: https://www.nordicin..._img/heggum.pdf

Edited by amazingboy, 20 September 2022 - 02:22 PM.

[Charles.C]

Dear Charles Chew,

(its quite simple really)

Over the last 5 years since ISO22000 was released, it surprises me why ppl remain confused over these terms.

I think the reason is "simple" Charles. The 22000/04 Standards are written (and/or translated) to confuse, except for consultants and auditors.

I am also beginning to suspect there is more than one "official" version of this Standard in common use, not including a Spanish edition which I recently encountered in another thread.

Attachment file is too big to upload - refer to: https://www.nordicin..._img/heggum.pdf

This is i think the same file (Heggum 2005) as in a simultaneously running parallel thread - http://www.ifsqn.com...dpost__p__28137

I anticipate you won't agree with my opinion there either but certainly interested to hear yr comments.

Whatever, very, very happy to see you posting on this topic.

Best Regards / Charles.C

[Charles Chew]

Dear Charles C.

If we do not have divergent in opinions, this forum would not have existed. No problem at all but i still feel your suspicion of "more than one official version" is rather outrageous though. Mind you, I do suspect a whole lot of consultants including auditors out there who are not quite competent as yet but having said that I myself is still on the learning curve myself despite having been in the industry for the last 20 years.

[Clemkonan]

Wow, and to think I was concerned that no one would reply. You have given me a great start sincere thanks.I took the 22000 lead auditor training

[Clemkonan]

I was starting to say I took the training but was not working in a ISO22000 environment, recently all that has changes so I have a lot of catching up to do

[Charles.C]

Dear clemkonan,

Thks yr response.

Very briefly, IMHO, many of the debates on the practical categorisation between CCP / OPRP have centred on (a) the intended conceptual meaning of OPRP, (b) making sense of the meaning of the terms 7.4.4 (a-g), © choice of prioritisation (if any) within the set 7.4.4 (a-g), (d) the meaning of “essential” and “likelihood” in the def.of OPRP as against its usage in para. 7.4.4.

Depending on yr process, the procedure IMO may be trivially easy or, if unlucky, perhaps less so.

Comments on the original Standard were sufficient to require the rapid release of iso 22004 which is recommended reading since this theoretically supercedes iso 22000. There is also a guidance document published by ISO which (I understand) is supposed to re-explain the CCP / OPRP implementation (amongst other things). Available from ISO website (at a price).
I suggest you use a consultant if encounter any major difficulties. Although yr surname should quell most auditor disagreements.

Good Luck!

Rgds / Charles.C