12 replies to this topic

[olgito]

Hello all! i am a master student and i have a course in international food legislation. i have a project to describe, for my company - manufacture yoghurt- certified by ISO 22000, aproposal for prerequisite programmes (PRPs) to be included in my food safetymanagement system.

Are these PRPs?!





1.Design and Construction of Buildings (exterior)

2.Location, grounds

3. Layout of Premises, Workspace, Employfacilities

4. Internal design, layout and structures(building interior, floor, windows, ventilation, glass)

5.Equipment Design and Location (processing, handling, storage, monitoring equipment)

6.Laboratory Facilities

7.Storage

8.Control of Water Supply, Control of Air Supply

10.Waste Management and waste disposal

11.Drainage Systems and pipes

12.Food Contact Surfaces

13.Equipment Cleaning programmes

14.Maintenance

15.Purchasing and supplier approval and monitoring

16.Control of Incoming Materials

17.Cleaning Programmes

18.Cleaning Agents and Equipment

19.Monitoring of Cleaning Effectiveness

20.Pest Control Programme

21.Prevention of Pest Access

22.Personal Hygiene

23.Personnel Hygiene Facilities

24.Personnel Canteen Facilities

25.Protective Work Wear

26.Medical Screening

27.Illness Reporting Systems

29.Product Recall

30.Product Recall

32.Warehousing Prerequisites

33.Dispatch and Distribution Prerequisites

34.Product Labelling

35.Personnel training



Moreover, i have to describe, for my company, a proposal for anoperational prerequisite programme targeting one microbial, one chemical, andone physical hazard (the given hazards for the project are Listeria ,antibiotics and metal bodies)

in the project according to the flow diagram of the yoghurt production we have microbial oPRP: storage of raw milk (temperature limit)

for physical and chemical we don't have oPRP only CCP (eg. pasteurisation for Listeria, packing with metal detector for metal objects, storage of raw milk negative for antibiotics or else we throw the milk)

What can it be oPRP? can it be the cleaning equipment (contamination), hand washing (contamination), pest control (rodents and listeria) or maintenance (metals)?

Thank you very much!

[Charles.C]

Dear Olgito,

Although I am not a direct user of ISO 22000, I think the answer to yr first part regarding prerequisites depends on which particular ISO 22000 publication you are referencing ?. The reason is that I believe the prerequisite requirement of recent, specific, sub-versions of ISO 22000 has been relatively formalised via the (prescriptive) prerequisite document PAS220 ?

Any specific answer regarding choice of OPRPs / CCPs rather depends on your hazard analysis, risk assessment, validation etc, they are not intrinsically generic quantities although many traditional HACCP plans will often agree on some types of actions being associated with CCPs. Opinions on OPRPs tend to be more variable, particularly as there are numerous methods for their categorisation as I’m sure you know already. Not to mention possible local legislatory factors.

One simple “formula” occasionally used on this forum is that if the proposed control measure for a (risk assessed) significant hazard does not meet the requirements for a CCP, then it must be associated with an OPRP. (This also assumes that the control measure can be validated as achieving yr [the standard’s] desired result for the final acceptable level of the hazard in the “end” product.). Whether this approach conforms to the standard’s defined textual implication that an OPRP should be related to a PRP is questionable. The pragmatic answer seems to be that, for current auditorial purposes, it doesn’t matter either way. IMO it is preferable that whatever “logical approach” is used, the implementation should not generate a horde of CCPs and/or OPRPs as was the problem with CCPs in early presentations of traditional HACCP plans.

There is an ongoing case study of the risk assessment related portion of ISO 22000 for a yoghurt process which may interest you. See this thread / link –

http://www.ifsqn.com...dpost__p__39585

Rgds / Charles.C

PS - maybe also hv a quick look at this parallel thread -

http://www.ifsqn.com...dpost__p__49289

PPS - Personally I would hv predicted NO to all yr last sentence queries in most properly designed systems but I expect you can easily find disagreements with this opinion on this forum.
How did you select yr suggested OPRPs ??

[olgito]

Thanks for your answer Charles!
Our project is a simple case with 3 hazards since we can't have real time plan for a real company, it's too complicated!
so my question basically is if those mentioned above are considered PRP's that i can include in my food safety management system .

in our project we have some oPRP's in some process steps of the production because we think that we can limit for example the growth of Listeria, is this considered oPRP?
or oPRP can be our pest control because rodents are hosts of Listeria for example?
our CCP is when we pasteurise because we think Listeria is eliminated, so is this an example of CCP?
Can you also please give me an example of how to document procedure for 7.10.3 Handling of potentially unsafe products?


My questions might seem really simple but the aim of the course is an introduction to all these and I have never had a course about legislation, standars or food safety management systems before so i am confused!

[Charles.C]

Dear Olgito,

IMO, yr questions are far from simple.

I assume you are referring to a retail final product.
It is important to remember that the standard’s use of CCP, OPRP, PRP is focused on control measures (CM) and for the first two also on significant process/environment hazards. Unfortunately the selection result is not always predetermined or black/white since processes vary and risk assessment (RA) / categorisation are subjective. Meaningful answers usually require details of the process/RA etc as per my previous post. Accordingly I hv given some (guessed) opinions below.

(1) Items 1-35 in yr list are probably possible prerequisites programs if referred to PAS220 (2008).

(2)

in our project we have some oPRP's in some process steps of the production because we think that we can limit for example the growth of Listeria, is this considered oPRP

Rather unlikely IMO but perhaps possible if occurring as environmental hazard for the process and justified by RA/etc details.

(3)

or oPRP can be our pest control because rodents are hosts of Listeria for example?

Unlikely IMO.

(4)

our CCP is when we pasteurise because we think Listeria is eliminated, so is this an example of CCP

Pasteurisation is often a valid process CM/CCP but it may depend on the process / RA details. (Note that Listeria is not an individual species, L.monocytogenes is a typical pathogen in the group).

Can you also please give me an example of how to document procedure for 7.10.3 Handling of potentially unsafe products?

I think this is already discussed somewhere in this forum but not sure. Maybe try a search.
(I note you hv already queried this here - http://www.ifsqn.com...dpost__p__49647 )

Rgds / Charles.C

[olgito]

Thank you again :) i've posted that one too,yes, trying to understand what is going on with food safety management systems etc. :)

[Jairajmarcose]

Please conduct your hazard analysis as usual according to codex.
identify significant hazards at each steps and their control measures first.


Use a proper decision tree for categorizing them for management using HACCP plans, OPRPs or PRPs

an example of such a tree can be found on the following link. There are others too and many certification agencies have their own trees.

http://www.docstoc.c...0-decision-tree

Regards
Jairaj  01.PNG   71.28KB   126 downloads

[Charles.C]

Dear Jairajmarcose,

Thks yr input.

Indeed there are many collections of decision trees referenced/posted on this forum due to varying interpretations of the ISO 22000 standard, including the Procert one in yr post. Unfortunately, none of them seem to well-fit all types of situations, just like the Codex tree in traditional haccp.

Please conduct your hazard analysis as usual according to codex.
identify significant hazards at each steps and their control measures first

It is possibly preferable to follow the steps given in the ISO 22000 standard. There are some differences (extras) to the Codex version.

Rgds / Charles.C

[Charles Chew]

[http://www.docstoc.c...0-decision-tree/quote]

This should put an end to this thread. The decision tree clearly covers the requirements under ISO 22000 as indicated by the relevant clauses. PRoCert is a foremost technical contributor to food safety. TQ Jaira.

[Charles.C]

[http://www.docstoc.c...0-decision-tree/quote]

This should put an end to this thread. The decision tree clearly covers the requirements under ISO 22000 as indicated by the relevant clauses. PRoCert is a foremost technical contributor to food safety. TQ Jaira.

Dear CharlesChew ,

The Procert tree appears to me to hv been designed to respond to the 3 suggested guideline requirements of ISO 22004 which, I presume, supercedes ISO 22000 regarding categorisation purposes. In view of the author’s pedigree, one must presumably have a measure of trust.

However I do not understand why it does not cover item © in ISO 22000/7.4.4 which appears rather critical IMO. Plus it’s adherence to “continuous” monitoring was, I think, mutually accepted as being “dilutable” many years ago.
(IMO, it is anyway unlikely that the necessary validation of the to-be-categorised control measure will be satisfactory if the monitoring aspect is not “feasible” ?.)

I can understand why the use of the basic Codex tree is so popular. For you also probably ?

Best Rgds / Charles.C

[Charles Chew]

[quoteHowever I do not understand why it does not cover item © in ISO 22000/7.4.4 which appears rather critical IMO. Plus it’s adherence to “continuous” monitoring was, I think, mutually accepted as being “dilutable” many years ago.
(IMO, it is anyway unlikely that the necessary validation of the to-be-categorised control measure will be satisfactory if the monitoring aspect is not “feasible” ?.)

I can understand why the use of the basic Codex tree is so popular. For you also probably ?

Best Rgds / Charles.C
[/quote]
Dear Charles C.
The identification of potential hazards and the relative risk categorization attached to such potential hazards conducted during hazard analysis would determine the level of risk management needed to be taken. This is where control measure(s)and or in combination thereof are determined / designed / established to satisfy the elements of Clause 7.4.4. The decision tree (whether it is Codex or ProCert does not address the design of control measure(s) specific BUT rather to identify CCP and or OPRP. To my knowledge, ISO 22004 (guidance document) has not been revised since released on 15/11/2005 and as such, no reference has been made where it should supercede ISO22000 and more so, I believe a guidance document is not designed to override a standard.

Attached Files

•  ProCert-ISO22000 -Decision Tree.pdf   124.35KB   88 downloads

[foodeng]

At my last audit, the auditor said that


The main difference is;


The critical points (not the critical control point) in your hazard risk evaluation list are called OPRP.

PRP are another list which are identified in the legistations that you can find in which country you live.

[Charles.C]

Dear Charles,

“Guidance on the application of” is, I suggest, a polite form of “guideline to”. The US-FDA are also quite fond of such semantic manouevres regarding delicate topics. Only UK organisations hv the bravado to issue new versions of the same standard within 1 year.

On the other hand, perhaps this ISO snippet I recently noticed does offer some (+/-) support to yr belief (albeit after 6 years of confusion) -

 extract.png   5.24KB   16 downloads

I deduce you disagree with my criticism of the Procert tree. No problem.

Rgds / Charles.C

[Charles.C]

Dear Charles C.
The identification of potential hazards and the relative risk categorization attached to such potential hazards conducted during hazard analysis would determine the level of risk management needed to be taken. This is where control measure(s)and or in combination thereof are determined / designed / established to satisfy the elements of Clause 7.4.4. The decision tree (whether it is Codex or ProCert does not address the design of control measure(s) specific BUT rather to identify CCP and or OPRP. To my knowledge, ISO 22004 (guidance document) has not been revised since released on 15/11/2005 and as such, no reference has been made where it should supercede ISO22000 and more so, I believe a guidance document is not designed to override a standard.

Dear Charles,

no reference has been made where it should supercede ISO22000 and more so, I believe a guidance document is not designed to override a standard

Can try this extract -

 ISO 22004 intention.png   114.79KB   8 downloads

Source -

 GFSI\'s role harmonising FS standards, Surak, FS Mag. 2009.pdf   2.61MB   61 downloads

Rgds / Charles.C