Interpreting CPs and OPRPs in BRC / FSSC
Started by Charles Chew, Sep 22 2011 11:35 AM
Dear All,
As it is, there is enough confusion out there on the understanding of OPRP. I am therefore asking for comments from practitioner of BRC-Food and or FSSC22000 (or ISO22000) to give me your comments on this topic. (I appreciate non-practitioners to take a step back for now)
Scenario - An integrated FSMS is in place comprising of BRC-Food and FSSC22000 where the control of known hazards are being monitored under the HACCP Plan and xxxx (i.e. CP or OPRP).
# Under BRC-Food (v5) - there is no mention of OPRP. So I assume all practitioners will be using the term CP
# Under FSSC 22000 - the term OPRP is used and loosely understood or largely misunderstood. CP is ignored in this instance.
Under this circumstance, would there be:
1. Confusion if OPRP is used in this integrated FSMS?
2. Relatively speaking, I believe BRC-Food is the leading Food Safety System - should the term CP be used and consequently replace the term OPRP and if so, does OPRP play the same role as CP?
3. If CP and OPRP can be used interchangeably in this integrated food safety system - does it mean that OPRP is CP and vice versa. If not, once again, what exactly the hell is OPRP
4. PRP - pre-requisite programmes (i.e. procedures, policies, etc)- no contest
* If data from monitoring records are needed to support evidence of control apart from the HACCP Plan in this intergated system, it has to be in the form of records. What should these records be "called or categorized" under this integrated BRC-Food / FSSC 20000 System i..e CP or OPRP or it does not matter because they both mean the same thing or is it?
Regards
Charles Chew
As it is, there is enough confusion out there on the understanding of OPRP. I am therefore asking for comments from practitioner of BRC-Food and or FSSC22000 (or ISO22000) to give me your comments on this topic. (I appreciate non-practitioners to take a step back for now)
Scenario - An integrated FSMS is in place comprising of BRC-Food and FSSC22000 where the control of known hazards are being monitored under the HACCP Plan and xxxx (i.e. CP or OPRP).
# Under BRC-Food (v5) - there is no mention of OPRP. So I assume all practitioners will be using the term CP
# Under FSSC 22000 - the term OPRP is used and loosely understood or largely misunderstood. CP is ignored in this instance.
Under this circumstance, would there be:
1. Confusion if OPRP is used in this integrated FSMS?
2. Relatively speaking, I believe BRC-Food is the leading Food Safety System - should the term CP be used and consequently replace the term OPRP and if so, does OPRP play the same role as CP?
3. If CP and OPRP can be used interchangeably in this integrated food safety system - does it mean that OPRP is CP and vice versa. If not, once again, what exactly the hell is OPRP
4. PRP - pre-requisite programmes (i.e. procedures, policies, etc)- no contest
* If data from monitoring records are needed to support evidence of control apart from the HACCP Plan in this intergated system, it has to be in the form of records. What should these records be "called or categorized" under this integrated BRC-Food / FSSC 20000 System i..e CP or OPRP or it does not matter because they both mean the same thing or is it?
Regards
Charles Chew
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Dear Charles Chew,
Or was the thread reserved for people who have implemented the current version of the standard(s) mentioned and been successfully audited ?
Rgds ./ Charles.C
PS I recall once posting a list of published "definitions" of CP, took up 2/3 of a page of A4.
A practitioner is someone who engages in an occupation, profession, religion, or way of life.
Or was the thread reserved for people who have implemented the current version of the standard(s) mentioned and been successfully audited ?
Rgds ./ Charles.C
PS I recall once posting a list of published "definitions" of CP, took up 2/3 of a page of A4.
Dear All,
As it is, there is enough confusion out there on the understanding of OPRP. I am therefore asking for comments from practitioner of BRC-Food and or FSSC22000 (or ISO22000) to give me your comments on this topic. (I appreciate non-practitioners to take a step back for now)
Scenario - An integrated FSMS is in place comprising of BRC-Food and FSSC22000 where the control of known hazards are being monitored under the HACCP Plan and xxxx (i.e. CP or OPRP).
# Under BRC-Food (v5) - there is no mention of OPRP. So I assume all practitioners will be using the term CP
# Under FSSC 22000 - the term OPRP is used and loosely understood or largely misunderstood. CP is ignored in this instance.
Under this circumstance, would there be:
1. Confusion if OPRP is used in this integrated FSMS?
2. Relatively speaking, I believe BRC-Food is the leading Food Safety System - should the term CP be used and consequently replace the term OPRP and if so, does OPRP play the same role as CP?
3. If CP and OPRP can be used interchangeably in this integrated food safety system - does it mean that OPRP is CP and vice versa. If not, once again, what exactly the hell is OPRP
4. PRP - pre-requisite programmes (i.e. procedures, policies, etc)- no contest
* If data from monitoring records are needed to support evidence of control apart from the HACCP Plan in this intergated system, it has to be in the form of records. What should these records be "called or categorized" under this integrated BRC-Food / FSSC 20000 System i..e CP or OPRP or it does not matter because they both mean the same thing or is it?
Regards
Charles Chew
I'm not a user or practitioner or whatever you want to call it, but I'd like to pose a couple of questions. I understand that you are doing an intergrated system, but....
1) What is the leading system between ISO 22000, FSSC, and BRC-Food? (However, I could be wrong and no leading system at all, but again, I doubt it.)
2) I also think wether you use OPRP or CP the implementation would be the same, so i guess your concern is related to documentation, isn't it?
I apologize if this hasn't really helped.
Hi MOM,
Thanks for sharing your opinion.
- Primarily, what I am trying to establish here is each system has its own terminologies but the functions are the same albeit the stringency within each reference scheme / standard, therefore, IMO,you are right in suggesting that it does not matter which is the leading standard and of course, as long as audit is conducted in an integrated manner vis-a-vis reference standard requirements1) What is the leading system between ISO 22000, FSSC, and BRC-Food? (However, I could be wrong and no leading system at all, but again, I doubt it.)
I have no concern at all with regards to documentations. We have partitioned the requirements of each reference standard clearly and developed a clear check list. Again IMO you are right in being on the same page i.e. whether the use of OPRP and CP, the implementation and their relative fundamentals / principles are IMO the same too. My concern is I have problems calibrating these two terminologies with some auditors2) I also think wether you use OPRP or CP the implementation would be the same, so i guess your concern is related to documentation, isn't it?
Thanks for sharing your opinion.
If I would be the auditor you can call it CP, OPRP, Dog, or Cat (joking) if you want to as long as all the requirements are met. Even if you have no concern with regard to documentation, you can address the issue in documentation. Decide what terminology to use (CP or OPRP?), then define it in your documented system. That way, everyone knows what it is, what it means, and how it works for your system.I have no concern at all with regards to documentations. We have partitioned the requirements of each reference standard clearly and developed a clear check list. Again IMO you are right in being on the same page i.e. whether the use of OPRP and CP, the implementation and their relative fundamentals / principles are IMO the same too. My concern is I have problems calibrating these two terminologies with some auditors
I wish these damn auditors would think the way you think and the whole world would then be at peace but this is often not to be. Nevertheless, thank you for your inputs which have been extremely satisfying enough for me to put this matter to rest. I consider this thread closed, done and dusted.If I would be the auditor you can call it CP, OPRP, Dog, or Cat (joking) if you want to as long as all the requirements are met. Even if you have no concern with regard to documentation, you can address the issue in documentation. Decide what terminology to use (CP or OPRP?), then define it in your documented system. That way, everyone knows what it is, what it means, and how it works for your system.
Dear All,
Scenario - An integrated FSMS is in place comprising of BRC-Food and FSSC22000 where the control of known hazards are being monitored under the HACCP Plan and xxxx (i.e. CP or OPRP).
Regards
Charles Chew
Hi Charles
The essence of your question is how do you combine the terminology and requirements of BRC and ISO 22000/FSSC 22000 to create a common system that complies with the requirements of both. So looking at the requirements of the two standards:
ISO 22000
Terms and Definitions
3.8 PRP prerequisite programme (food safety) - basic conditions and activities that are necessary to maintain a hygienic environment throughout the food chain (3.2) suitable for the production, handling and provision of safe end products (3:5) and safe food for human consumption
3.9 Operational PRP - operational prerequisite programme PRP (3.8) identified by the hazard analysis as essential in order to control the likelihood of introducing food safety hazards (3.3) to and/or the contamination or proliferation of food safety hazards in the product(s) or in the processing environment
3.10 CCP critical control point (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
3.15 Validation (food safety) - obtaining evidence that the control measures managed by the HACCP plan and by the operational PRPs
are capable of being effective
3.16 Verification - confirmation, through the provision of objective evidence, that specified requirements have been fulfilled
7.2 Prerequisite programmes (PRPs)
7.2.3 The organization shall consider the following when establishing these programmes:
- Construction and lay-out of buildings and associated utilities
- Lay-out of premises, including workspace and employee facilities
- Supplies of air, water, energy and other utilities
- Supporting services, including waste and sewage disposal
- The suitability of equipment and its accessibility for cleaning, maintenance and preventative maintenance
- Management of purchased materials, supplies, disposals and handling of products
- Measures for the prevention of cross contamination
- Cleaning and sanitizing
- Pest control
- Personnel hygiene
- Other aspects as appropriate
Verification of PRP(s) shall be planned
For FSSC 22000 Certification PAS 220/TS ISO 22002 specify detailed requirements to be considered in relation to 7.2.3 of BS EN ISO 22000:2005, specifically:
- Construction and layout of buildings and associated utilities
- Layout of premises, including workspace and employee facilities
- Supplies of air, water, energy and other utilities
- Supporting services, including waste and sewage disposal
- Suitability of equipment and its accessibility for cleaning, maintenance and preventive maintenance
- Management of purchased materials
- Measures for the prevention of cross contamination
- Cleaning and sanitizing
- Pest control
- Personnel hygiene
In addition other aspects which are considered relevant to manufacturing operations are included:
- Rework
- Product recall procedures
- Warehousing
- Product information and consumer awareness
- Food defence, biovigilance and bioterrorism
7.4.4 Selection and assessment of control measures
The control measures selected shall be categorized as to whether they need to be managed through operational PRP(s) or by the HACCP plan.
7.8 Verification planning
The verification activities shall confirm that
- PRP(s) are implemented
- OPRP(s) and the elements within the HACCP plan are implemented and effective
8.2 Validation of control measure combinations
Prior to implementation of control measures to be included in operational PRP(s) and the HACCP plan the organization shall validate that the selected control measures are capable of achieving the intended control of the food safety hazard(s)
BRC Global Standard for Food Safety Issue 6
Glossary
Critical Control Point – The step at which control is applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level
Control Point – Not described
Operational Prerequisite Programme – Not described
Prerequisite – The basic environmental and operations that are necessary for the production of safe food. These control generic hazards covering good manufacturing practice and good hygienic practice and shall be considered within the HACCP study
Validation – Confirmation through the provision of objective evidence that the requirements for the specific intended use or application have been fulfilled
Verification - Confirmation through the provision of objective evidence that specified requirements have been fulfilled
BRC Issue 6 is prescriptive with regards to the Prerequisite Programmes required but is not so much with regards to the terms used. Firstly in Section 2 The Food Safety Plan – HACCP Clause 2.2 there is a requirement to establish and maintain environmental and operational prerequisite programmes. These include:
- Cleaning and sanitising
- Pest control
- Maintenance programs for equipment and buildings
- Personal hygiene requirements
- Staff training
- Purchasing
- Transportation arrangements
- Processes to prevent cross contamination
- Allergen controls
These prerequisites require documented control measures and monitoring procedures.
Furthermore Clause 2.7.3 requires that when control is achieved through prerequisite programmes the adequacy of the programmes in controlling the hazard this should be stated (documented) and validated. Combinations of control measures should be taken into consideration in this process.
Clause 2.9.2 requires the HACCP Food Safety Team to validate each CCP. Documented evidence needs to show that the control measures and critical limits identified are capable of consistently controlling the hazard to the specified acceptable level.
Elsewhere the standard prescribes that there should be systems and procedures. BRC Issue 6 also prescribes that risk assessments are required in certain areas including:
- 3.6.1 Supplier Approval
- 4.2.3 Secure Production and Storage Areas. Restricted and Sensitive Areas
- 4.2.4 Secure Ingredient Storage
- 4.2.4 Secure Packaging Storage
- 4.2.4 Secure Chemical Storage
- 4.2.4 Secure Equipment Storage
- 4.3.1.4 Cleaning or Production Utensils
- 4.4.2 Water, Ice, Steam, Air, Compressed Air, Other Gases
- 4.6.2 New Equipment & Plant Maintenance Program
- 4.7.1 Assess risk where there is not direct access to product areas
- 4.8.1 Risk of Chemical, Physical or Taint Contamination of Product
- 4.8.1 Verification audits of controls for Risk of Chemical, Physical or Taint Contamination of Product
- 4.8.4 Risk assessment of control of Glass/Hard Plastic
- 4.8.4.2 Frequency of checks of brittle materials
- 4.8.4.3 Risk assessment for control of breakage's of brittle materials
- 4.8.5.1 Risk of Wood Contamination
- 4.8.6.2 Procedures to minimise risk of Foreign Body Contamination of Packaging
- 4.11.2 Frequency of Pest Inspection
- 4.12.1 Procedures for Storage of Product based on risk assessment
- 4.12.1 Procedures for Loading of Product based on risk assessment
- 4.12.1 Procedures for Transport of Product based on risk assessment
- 5.2.1.1 Allergens in Raw Materials
- 5.2.1.3 Allergen Contamination Routes
- 5.2.1.6 Equipment & Area Cleaning Procedures (Allergens)
- 5.2.2.1 Risk assessment of IP Raw Materials
- 5.2.2 Identity Preservation Contamination Routes
- 5.5.1.1 Testing and Inspection Schedules
- 5.7.1 Product Release
- 6.3.2 Frequency of Verification/ Calibration of Measuring Devices
- 7.3.2 Jewellery Policy
- 7.3.4 Hand Cleaning
- 7.5.1 Rules for wearing and changing Protective Clothing
- 7.5.4 Washing of Work wear by Employees
- 7.5.7 Risk of contamination from Facial Hair & necessary controls
Clause 2.12.1 requires verification that controls managed by prerequisite programmes are effective.
Overall the BRC Global Standard for Food Safety Issue 6 is far more extensive in prescribing food safety and prerequisite programme requirements most of which are included in the following sections:
Section 3 Food Safety and Quality Management System
Section 4 Site Standards
Section 5 Product Control
Section 6 Process Control
Section 7 Personnel
In many ways I agree with Mind Over Matter that providing everyone understands what the terms mean it doesn't really matter what you call them. However, if you require a certified system that covers the requirements of both standards I would use ISO 22000 terminology in developing a system whilst considering the extensive prerequisite requirements of the BRC Global Standard for Food Safety.
Kind regards,
Tony
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Hi Tony, Thank you for responding. Indeed, we applied exactly the same implementation strategy as you have suggested covering the extended requrements under the BRC - Food Scheme. We had to do a lot of cross referencing to build the checklist. BTW, we applied PAS220 instead of ISO22002 for PRP ungrades.However, if you require a certified system that covers the requirements of both standards I would use ISO 22000 terminology in developing a system whilst considering the extensive prerequisite requirements of the BRC Global Standard for Food Safety.
Are you still operating from Koh Samui? Was there last month to do some diving at Koh Tao.
Hi Charles Chew,
Speaking purely as an ISO observer rather than an implementer it seems to me that “pure” ISO 22000 is now marginalised. Although this is not necessarily saying that FSSC will be a proportional winner.
It looks like ISO 22000's inventors are determined not to revise any of the original standard's text.
I suppose ISO 22004 was a sort of hasty appeasement to users for the original shortcomings which, I presume, became rapidly and painfully obvious to implementers (and auditors?). The conclusion AFAIK for categorising OPRP/CCP was that any “logical” interpretation of the textual requirements could be used. So welcome back “Codex”.
Then GFSI / the “market” / PAS 220 / FSSC forced the sideways issuance of the new (Prerequisite-driven) ISO series.
For BRC / 22000 I guess that for many simple systems the involvement of OPRP is (or can be made) negligible if one wishes.
I would guess that the greatest benefits of the OPRP introduction have perhaps been for certain product situations, eg non-killing pathogen processes where many people previously used the “minimising risk” CCP interpretation instead. (newer versions of “CCP” hv also tried to fill this gap). (Whether this relates to the original standard's primary intentions I'm not sure.) Such cases must be a little more difficult to BRC/22000 integrate perhaps?.
The Codex-type decision-making route for OPRP/CCP is surely a perfect option if blending 22000 into a joint BRC environment.
One discussion topic which has so far been surprisingly (to me anyway) neglected is how to optimally minimise the combined sum of (OPRP+CCP)s. (In present case, this presumably becomes initially a minimisation of OPRPs.)
My only generic implementation comment is that I sincerely hope that people do not get so fascinated by all the current Prescriptive Opportunities that they simply forget to “do” haccp.
Hope these observations were not too far off – topic.
Rgds / Charles.C
Speaking purely as an ISO observer rather than an implementer it seems to me that “pure” ISO 22000 is now marginalised. Although this is not necessarily saying that FSSC will be a proportional winner.
It looks like ISO 22000's inventors are determined not to revise any of the original standard's text.
I suppose ISO 22004 was a sort of hasty appeasement to users for the original shortcomings which, I presume, became rapidly and painfully obvious to implementers (and auditors?). The conclusion AFAIK for categorising OPRP/CCP was that any “logical” interpretation of the textual requirements could be used. So welcome back “Codex”.
Then GFSI / the “market” / PAS 220 / FSSC forced the sideways issuance of the new (Prerequisite-driven) ISO series.
For BRC / 22000 I guess that for many simple systems the involvement of OPRP is (or can be made) negligible if one wishes.
I would guess that the greatest benefits of the OPRP introduction have perhaps been for certain product situations, eg non-killing pathogen processes where many people previously used the “minimising risk” CCP interpretation instead. (newer versions of “CCP” hv also tried to fill this gap). (Whether this relates to the original standard's primary intentions I'm not sure.) Such cases must be a little more difficult to BRC/22000 integrate perhaps?.
The Codex-type decision-making route for OPRP/CCP is surely a perfect option if blending 22000 into a joint BRC environment.
One discussion topic which has so far been surprisingly (to me anyway) neglected is how to optimally minimise the combined sum of (OPRP+CCP)s. (In present case, this presumably becomes initially a minimisation of OPRPs.)
My only generic implementation comment is that I sincerely hope that people do not get so fascinated by all the current Prescriptive Opportunities that they simply forget to “do” haccp.
Hope these observations were not too far off – topic.
Rgds / Charles.C
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Dear all,
Well, in my personal opinion,
The most effective way to convince auditor is referencing the relevant terminology.
According to terminology in the post by Tony-C, the definition of oPRP is very similar to "CP" definition in IFS standard. Thus it is possible to combine the concept of both standards into one incorporated checklist/QMS etc..
Furthermore, in repective of the Concept "CP" or "OPRP", the implementation of all control measures should be the most important thing.
Best regards,
Jason
Well, in my personal opinion,
The most effective way to convince auditor is referencing the relevant terminology.
According to terminology in the post by Tony-C, the definition of oPRP is very similar to "CP" definition in IFS standard. Thus it is possible to combine the concept of both standards into one incorporated checklist/QMS etc..
Furthermore, in repective of the Concept "CP" or "OPRP", the implementation of all control measures should be the most important thing.
Best regards,
Jason
Dear Jason,
Slightly
Out-of-curiosity, what is the IFS definition of a "Control Point".? I deduce that it is also related to the conclusions of the hazard analysis.
Rgds / Charles.C
Slightly
Out-of-curiosity, what is the IFS definition of a "Control Point".? I deduce that it is also related to the conclusions of the hazard analysis.
Rgds / Charles.C
Dear Jason,
Slightly
Out-of-curiosity, what is the IFS definition of a "Control Point".? I deduce that it is also related to the conclusions of the hazard analysis.
Rgds / Charles.C
Dear Charles,
As I know, IFS Food version 5 definition for CP is "Identified by the hazard analysis as essential in order to control the likelihood of introducting or proliferation of food safety hazard in the product and/or the environment."
Thus personally think it is similar as the definition of OPRP in ISO 22000.
Best regards,
Jason
If CPs and OPRPs are of the same meaning or pursue, then Charles Chew needs to do is t decide what terminology to use (OPRP or CP?) and so the documentation are technically correct. But it seems that this is not the case.Dear Charles,
As I know, IFS Food version 5 definition for CP is "Identified by the hazard analysis as essential in order to control the likelihood of introducting or proliferation of food safety hazard in the product and/or the environment."
Thus personally think it is similar as the definition of OPRP in ISO 22000.
Best regards,
Jason
The above posts are all well reasoned and valid, but what is becoming evident is that the language of HACCP has become self breeding and is danger of taking priority over the risk assessments and the manufacture of safe food.
It has been stated elsewhere on the forum (including by me) that it shouldn't matter what you call the risk, just as long you control it correctly and can prove that you have done so.
It has been stated elsewhere on the forum (including by me) that it shouldn't matter what you call the risk, just as long you control it correctly and can prove that you have done so.
Dear Jason,
Thks yr info. re IFS, I did some searching after my previous post and located a summary of the IFS-5 standard however this only referred to the possible use of CPs but without describing what they are. I presume yr quoted definition is in the glossary.
If you are correct, I agree that the IFS team seem to have been impressed by ISO 22000-OPRP (or perhaps the other way round ?
Logically, one would think an OPRP should also be conceptually relatable to a PRP. I noticed this sort of illustrated in this interpretation of IFS for auditors –
ifs 2.1.3.5.png 23.17KB 7 downloads
Rgds / Charles.C
PS - As an example of a simpler haccp usage of “CP” (and how to differentiate it from CCP), can hv a look at this reference –
haccp in blueberry production - blue_manual.pdf 407.17KB 88 downloads
(see pgs 10, 35-37)
PPS, Apologies again Charles Chew, above is OT for sure.
Thks yr info. re IFS, I did some searching after my previous post and located a summary of the IFS-5 standard however this only referred to the possible use of CPs but without describing what they are. I presume yr quoted definition is in the glossary.
If you are correct, I agree that the IFS team seem to have been impressed by ISO 22000-OPRP (or perhaps the other way round ?
Logically, one would think an OPRP should also be conceptually relatable to a PRP. I noticed this sort of illustrated in this interpretation of IFS for auditors –
ifs 2.1.3.5.png 23.17KB 7 downloads
Rgds / Charles.C
PS - As an example of a simpler haccp usage of “CP” (and how to differentiate it from CCP), can hv a look at this reference –
haccp in blueberry production - blue_manual.pdf 407.17KB 88 downloads
(see pgs 10, 35-37)
PPS, Apologies again Charles Chew, above is OT for sure.
Hi MOM, I had raised the issue of OPRP and CP merely to gather the thoughts of forum members and was keen to know the degree of divergence amongst members with these terminologies which seem to be giving ppl a whole of trouble. Frankly, the documentation that we established for our client was never changed, the terminologies remained as suggested (OPRP was used as the primary terminology) and the result of a 3-day compliance audit took the client to FSSC22000 and BRC (issue 5) Grade A certification .... TODAY. Well, be it OPRPs or CPs - its history as far as I am concern.If CPs and OPRPs are of the same meaning or pursue, then Charles Chew needs to do is t decide what terminology to use (OPRP or CP?) and so the documentation are technically correct. But it seems that this is not the case.
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