For Control Measures how should we describe oPRP's?

I think there is general agreement that PRPs , oPRPs and CCPs are control measures meaning that these are associated with actions or activities that prevent or eliminate a food safety hazard, or reduce it to an acceptable level. Also most folks may only want to include CCPs and oPRP in that definition.
My question is this, for CCP life is easy , each CCP is associated with a critical limit statement but for an oPRP what is the correct language to use in the hazard analysis to say that a similar statement or specification is needed ( e.g 100 micron screen, negative allergen test) to describe the thing driving the oPRP? Thinking of Form 10 and FSEP

I think there is general agreement that PRPs , oPRPs and CCPs are control measures meaning that these are associated with actions or activities that prevent or eliminate a food safety hazard, or reduce it to an acceptable level. Also most folks may only want to include CCPs and oPRP in that definition.
My question is this, for CCP life is easy , each CCP is associated with a critical limit statement but for an oPRP what is the correct language to use in the hazard analysis to say that a similar statement or specification is needed ( e.g 100 micron screen, negative allergen test) to describe the thing driving the oPRP? Thinking of Form 10 and FSEP

Dear Clemkonan,

You may be having some confusion over terminologies. CCP is not a control measure.

Sorry if I have misunderstood but I think you are asking what “term” replaces “critical limits” (as defined for CCPs) if one is discussing oprps ?

IMO it’s a question of chronology. In ISO22000 it is necessary to first validate the proposed control measure’s (CM’s) basic ability to acceptably control the (significant) hazard (target is pre-defined). This typically requires a choice of “limits” related to “something” [or possibly not?]. The CM is then evaluated / categorised as included within (a) a haccp plan or (b) an OPRP program. If result is (a) any validated limits are specified as “critical limits”, if (b) I guess it’s up to you. (note that standard's sec.7.5 implies the possibility of non-existence of obvious limits).

Rgds / Charles.C

Hi Clemkonan

I agree with Charles in the definition of a CCP. For each CCP you have a critical limit, monitoring, corrective action, records and verification activities. CCPs have been defined as an outcome of your hazard analysis and generally relate to micro, chemical, physical, allergenic hazards. What I then tend to see as an auditor is a further determination of regulatory hazards and quality hazards.

Regulatory hazards (when assessed as critical) generally get called RCP (Regulatory control points or regulatory critical points) and quality hazards (when assessed as critical) generally get called QCP (Quality control points or quality critical points).

When you are looking at your support programs or prerequisite programs (PRPs) the first step is to ensure that you have validated that the control measure is going to actually control/reduce/eliminate the identified hazard. Secondly, you would then verify that you are doing what you say you are going to do.

This is just a really simple example but I hope you can get the jist of what I am trying to say:

Example: Cleaning Program - the purpose of having a cleaning program in place is to reduce the risk of micro growth, prevent OHS issues, prevent cross contact (for allergens) and cross contamination (micro), prevent pest infestation, prevent foreign matter contamination. An example validation would be to ensure that the cleaning chemicals at x concentration you use in the cleaning process are going to control/kill/reduce pathogens/microbes. The verification activity would be to check that the chemicals have been applied correctly.

It is good practice to have a document that supports any of your PRPs whereby it states the basis of why the control is going to work (validation) and then how you are going to ensure that the control is still working (verification).

The other way that I look at this stuff is when you do your hazard analysis and apply a control measure (as required by Codex HACCP), if the hazard is subsequently rated as not significant or not critical (if you have further used the Codex CCP Decision Tree) - the control measure gets placed into a PRP.

Hope this helps and I hope I have not confused you further.

Cheers
Amanda