Can the absence of a oPRP trigger a NC

Does the ISO22000 standard give the assessor any ammunition to make a finding if the client has opted not to use an oPRP say a filter managing FM at a filler and instead chooses to use a generic PRP and how would the case for objective evidence be constructed?

How would the reasoning differ say from the filler where sanitation is reducing a hazard but again a PRP , namely sanitation is being used?

Similalry an extension of this would be that there are two filters "A" and "B" both located pre filler but "B" for lack of a better word is the " terminal" filter, its the final "gate keeper"

Does it make sense to say its not a oPRP because ..... its not a choking hazard .....it only provides a partial reduction not elimination, etc.

Thanks
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Dear clemkonan,

You omit to detail the actual process which limits the answer somewhat.

Does the ISO22000 standard give the assessor any ammunition to make a finding if the client has opted not to use an oPRP say a filter managing FM at a filler and instead chooses to use a generic PRP and how would the case for objective evidence be constructed?

(Slightly OT but some people would classify the filter as a CCP, depending on its [competently monitored] result of course) .

I suggest you select a specific alternative as example. I thought that the designation of “prp” was closely prescribed these days, eg it would not (normally) include filtration as per yr comment although one could consider it as a system-wide prp perhaps (cf chlorination for example) (it depends on the situation).

The "objective evidence" presumably equals validation which will also depend on what you are talking about, eg has someone else demonstrated/published that “it” “works”.

Yr multiple filter case has appeared here before (for traditional haccp) in the format of having 3 identical units in series with the second and third as backups in case of failure of No.1 which is 100% capable of elimination. A long discussion ensued.
Assuming all 3 filters are (actively)in play and achieve elimination of the hazard, simpler to regard as a combination IMO. Individual analysis is also possible (allowed) but maybe superfluous (especially if the interplay is unknown!), it depends. Again, some people may classify the combination as CCP, not oprp.

Hope the above not too confusing. From a purely auditorial aspect, it is usually safer to use textbook answers where possible, unless you prefer arguments. Assuming one suitable (quotable) textbook answer exist of course.

Rgds / Charles.C

Dear clemkonan,

Your comments (if any) seem to have disappeared ???

Rgds / Charles.C