Charles:
Thank you for your thoughts. These are good discussions to have. You do make a good point; a company may simply implement some oPRPs in order to meet the standard, and not produce product that is any safer for it as a result.
Can I ask what OT means? My only knowledge of the term is "overtime."
The reason I believe that the concept may improve companies' HACCP systems is because it formally recognizes what is already being done by many companies in practice, and has been for many years. It recongnizes that in addition to fundamental environmental controls like pest control, and CCPs, there are process steps in the "middle" of this continuum that must also be controlled with a level of rigor. They're often called "quality control points" or just "control points." Well-concieved HACCP plans will, I believe, include these control points as something that is monitored, making the product safer. Companies that do not monitor these points in the process (I believe there are many) increase the likelihood of producing an unsafe product.
To clarify, as an example, if you have a 5-log reduction "kill step"in your process and you are refrigerating raw product for a brief period prior to the kill step, this refrigeration may not be recognized in your HACCP plan as a CCP. However if the refrigeration is not monitored and goes out of compliance long enough to produce a material with a 6-log count of microorganisms, you may be putting consumers at risk. This is just a made-up example off the top of my head, and may not be the best example.
Some food safety standards may directly require what they consider to be universal oPRPs, such as the glass & hard plastic policy requriements of the BRC and IFS. But they don't necessarily require that you implement control points specific to your particular process.
The way I see it, this concept more specifically calls out an industry best practice that is not clearly required anywhere else. It may require more paper (or more bytes of spreadsheet), but I believe it's the right thing to do. Just my two cents.
Jon
Dear Jon,
Slightly OT 
,
Not sure exactly what you mean by robust. No offence intended but redundant is more the word that comes to my mind.
Personally, I have yet to see any claim, let alone objective evidence, that the introduction of OPRP has achieved any specific benefit with regards to food safety compared to traditional HACCP ? (Other than to boost paper usage perhaps).
Admittedly this lack may partly be due to the fact that the relevant text was concocted with such ambiguity that food safety forums are still arguing/ wasting their time (?) over the intended basic meaning 5 years later. I suppose one can at least give credit to ISO for internationally breaking the KISS concept.
If ISO had to proceed in the present 22000 direction, it would probably have been so much easier to simply present, with examples, a suitably modified version of Dutch HACCP as their chosen form in place of Codex. And rewrite/delete much of the gobbledygook of the notorious paragraphs (a-g).
Rgds / Charles.C
