7 replies to this topic

[jcri]

Dear All,

I am a bit confused about some of the oPRP characteristic. One of the main differences between oPRP program and HACCP program is the fact that for oPRP there are not critical limits to be established.

This gives me some problem to decide in which of the two categories some of the hazard fall into.

For example for make sure that there are not residues of caustic left after a CIP we check the PH of the final rinse water (must be PH<8). This hazard could be included in the oPRP program because is a general control measure that is applied in many area of the production. But the fact that there are critical limits (PH<8) in place made it a CCP.

I would really appreciate if anyone can give me an advice about this issue.

Thank you.

Jcri




 

[Charles.C]

Dear jcri,

CIP will normally be one of your prerequisite programs. By definition.

Rgds / Charles.C

[D-D]

Try calculating the Risk score by a multiplication of Severity (how bad if it happens) and Likelihood (how often it happens) as a standard risk assessment.
Your cleaning method should be validated to ensure you always pass the pH test and any borderline results would be diluted out in the next run anyway so the Risk score will always be very low = automatic PRP. If you do this with all your hazards and only put the medium-high scores through the decision tree it should show the CCPs and all the low scores are PRPs.

[Charles.C]

Dear jcri,

Thought I should add a little more explanation. Apologies in advance if you know all this already.

The penultimate versions of ISO 22000 included oprps for certain specific sanitation control aspects and in principle, as you stated, the standard still maintains such a possibility, especially where there is a significant hazard envisaged. (In fact there is a lengthy (conceptual) thread on this forum discussing the possibility of “handwashing” being an OPRP ). The final published version of the ISO2200 standard incorporated a few apparent "re-thinks" regarding the interpretation / determination of oprps, the typical user result being, IMHO, confusion. ISO shortly issued ISO 22004, a "Guidance" document which included some clarifications regarding categorisation of oprps. Another ISO document (2006) discussed the intended scope / sourcing of oprps -
 ISO22000 blanc 2006 - some comments on implementation.pdf   275.29KB   397 downloads

Since, AFAIK, the idea of Prerequisites is hopefully to simplify the design of the FSMS, it is initially preferable IMO to simply follow the logic of the standards clause on selecting Prerequisites and include the operational aspects you mention within the prerequisite program(s).

A significant failure in the performance of a prerequisite will typically be highlighted within the “Verification” function so that further responses can be applied as per the relevant standard’s clauses, eg reviewing/revising/updating the HACCP plan as appropriate.

It is also true as you noted that traditional HACCP/CCPs tended to rely on readily quantifiable critical limits, the absence of such being one motivation for the invention by ISO22000 of OPRPs. However the lack of critical limits can be somewhat of a “red herring” since in practice it is rather difficult to validate control measures without some form of “operational” criteria, be it qualitative or quantitative.

Nowadays, the specific determination of OPRPs usually tends to initially focus on the text starting at clause 7.4.4 after determining the significant hazards from the hazard analysis (7.4.3). IMEX, it is tacitly assumed that if a prerequisite function is satisfactorily implemented, it’s associated safety risk will be non-significant due to a low likelihood of occurrence. (in a sense, the prerequisite option acts as a “by-pass”, early HACCP plans without prerequisite functions often had “Sanitation” CCPs all over the place).

PAS220, now known as ISO/TS 22002-1, represents a jumbo compilation of GFSI, and “ISO- acceptable” Prerequisites, but postdates ISO22000. However it now seems to also be in use as a support document to ISO22000 in addition to FSSC22000 ( ), (eg –
http://www.22000-too...mmes-22002.html ). PAS220 specifically includes CIP.

Hope the above is intelligible/useful.

Rgds / Charles.C

[Tony-C]

Dear All,

I am a bit confused about some of the oPRP characteristic. One of the main differences between oPRP program and HACCP program is the fact that for oPRP there are not critical limits to be established.

This gives me some problem to decide in which of the two categories some of the hazard fall into.

For example for make sure that there are not residues of caustic left after a CIP we check the PH of the final rinse water (must be PH<8). This hazard could be included in the oPRP program because is a general control measure that is applied in many area of the production. But the fact that there are critical limits (PH<8) in place made it a CCP.

I would really appreciate if anyone can give me an advice about this issue.

Thank you.

Jcri

Hi Jcri,

As Charles has indicated this sort of hazard is normally controlled by your prerequisite programme - 'cleaning/CIP'. The likelihood this hazard is reduced by use of food grade chemicals, automated CIP, CIP settings being controlled & CIP verification.

Your check of adequate rinsing is not unusual as a simple pH check is quick and cheap. This hazard would also be reduced by checks of 1st off product and 1st product off being discarded if you do that.

So when you assess the hazard your prerequisites reduce the likelihood and severity of the hazard such that it is not significant and not regarded as a CCP nor an OPRP.

Kind regards,

Tony

[MILA68]

Dear all,

 

This issue with PRPS further being catergorised as oPRP's, is taking it a bit too far! , its confusing and a matter of opinion and interpretation. why can there just not be a definative answer? . Yes or No...or better yet is there a list of definative oPRP'S?

 

You end up having auditors creating so much doubt in your own system , you end up re- viewing.your risk assessment many times over!!.

 

Mila68

[mahantesh.micro]

Dear All,

I am a bit confused about some of the oPRP characteristic. One of the main differences between oPRP program and HACCP program is the fact that for oPRP there are not critical limits to be established.

This gives me some problem to decide in which of the two categories some of the hazard fall into.

For example for make sure that there are not residues of caustic left after a CIP we check the PH of the final rinse water (must be PH<8). This hazard could be included in the oPRP program because is a general control measure that is applied in many area of the production. But the fact that there are critical limits (PH<8) in place made it a CCP.

I would really appreciate if anyone can give me an advice about this issue.

Thank you.

Jcri
 

Dear JCRI

OPRP can be either measurable or observable. U can still make pH of caustic in final rinse water as OPRP.

See below (ISO 22000-2018)

action criterion

measurable or observable specification for the monitoring (3.27) of an OPRP (3.30)

operational prerequisite programme

OPRP

control measure (3.8) or combination of control measures applied to prevent or reduce a significant food safety hazard (3.40) to an acceptable level (3.1), and where action criterion (3.2) and measurement (3.26) or observation enable effective control of the process (3.36) and/or product (3.37)

 

Clause 8.5.4.2 : Action criteria for OPRPs shall be measurable or observable. Conformance with action criteria shall contribute to the assurance that the acceptable level is not exceeded.

 

Edited by mahantesh.micro, 20 June 2019 - 06:24 AM.

[Charles.C]

7-year old thread.

 

If one compares the interpretations of oprp in 2nd edition iso22000 to the first, it is obvious that iso have now deleted the mysteriously subjective prose which confounded so many, many people. So mysterious that iso22004 had to be generated almost immediately to attempt to rationalise the original text.

 

@ Mila, yr comments et al were a reason for appearance of fssc22000/PAS220.

 

It is an unfortunate characteristic of such iso standards that their generic intention tends (IMO) to produce incomprehensibility.