Sorry Charles. I should have been more specific! Yes, I'm aware of the PAS-223 Specification. Our Receiving, Warehousing & Transportation program (among others) was implemented prior to us obtaining the PAS 223 Specification. I conducted a gap analysis on our previously implemented programs to the PAS 223 Specification and adjusted the procedures accordingly. The part that is really confusing me is actually determining what an OPRP is? I've read that PRP's are the basic activities & conditions needed to maintain a hygienic environment. If this is true then why does PAS 223 (Prerequisite Programs for packaging manufacturers) contain programs such as purchasing & withdrawal?? Is an OPRP more of a specific activity or point such as CCP's? I'll go back to the allergen management example. Allergen mislabeling due to graphics control is a common hazard associated with printed packaging materials. This is controlled by our Allergen Management Program / PAS223. Where do OPRP's come into play here? As I assess hazards, virtually all of them are contolled by programs within the PAS 223 specification. I would love to see a documented hazard analysis that has examples of a hazards controlled by PRP's, OPRP's as well as CCP's. I had a good understanding of HACCP & the Codex principles before OPRP's were thrown into the mix!
I would love to see a documented hazard analysis that has examples of a hazards controlled by PRP's, OPRP's as well as CCP's
I have to ask another 2 questions –
(1) Are you aware of this thread which was specifically intended to attempt an answer to the above question ? It is food-based but the conceptual logic is, probably (?), interchangeable if you replace PAS220 by PAS223 (I admit i haven't tried it out for packaging though .
(2) Have you read iso22004 ? This “clarifies” OPRP although unfortunately only by avoiding specificity (have to remember that ISO is a generic-oriented organisation, ie non-prescriptive).
Having said this, yr question mirrors so many old / new threads here and perhaps defines an 8yr failure (and counting) in the iso22000 standard. Maybe the earlier / just released iso guidebooks address(ed) it but I have never seen them evaluated regarding this aspect so probably not ?. The inevitable consequence is that a spectrum of interpretations as to “what is OPRP” exist ranging from the most simple to the somewhat opposite in respect to "necessary associated documentation" and "conceptual" complexity. The range is illustrated in ( at least) 2 very (notoriously) long threads here which everybody is probably bored with so no need to restate again.
[Just as an example the most simple viewpoint here is exemplified by an oldish post from CharlesChew which is (paraphrasing, apologies to CC) something like – after the hazard analysis, a (relevant) control measure is either a CCP or OPRP. So if it fails the [codex] test for CCP, what can it be other than an OPRP ? This answer maybe ignores the subtleties of the intended conceptual theory ( semantics?) in the 22000 / 22004 standards but seems to be auditorially accepted as a valid operational solution. Maybe implicitly accepts that the auditorial community don’t really understand what OPRP means also .
Some more detailed solutions are in the 2 threads mentioned above and loads of other places, eg the French Literature (I previously posted one elaborate example in an older thread here) or perhaps The IFSQN treatment within the commercial package offered here ( this [I understand from posts here] uses a “system” OPRP approach to avoid over-complexity in documentation aspects)]
Why does PAS 223 (Prerequisite Programs for packaging manufacturers) contain programs such as purchasing & withdrawal?
It is subjective of course (eg see a parallel thread here on SSOPs). See the early PRP literature for other examples. i also find some of the inclusions a little tenuous in respect to maintaining "good hygienic conditions". I suppose a degree of expansion from GHP to GMP has quietly occurred.
This is controlled by our Allergen Management Program / PAS223. Where do OPRP's come into play here?
I guess this was rhetorical? .
To summarise, IMO, OPRP is a control measure defined in ISO22000 but whose interpretation (eg 22004) has chronologically changed since its inception pre-2005. Currently, in the English Literature, it is operationally (ie for auditorial purposes) mostly determined by the methods given in various places in this forum, now particularly via additional use of the PAS-ISO (PRP) documents. Conceptually, it’s up for grabs .
Addendum - One perhaps important aspect but normally not discussed is -
How many OPRPs should there be ?
This will vary depending on the conceptual approach.
In my link given above, there are none. Some people (auditors?) may find this unacceptable. Opinions are welcomed.
Iso 22004 says the question is ultimately (operationally) irrelevant since can tag (significant) control measures as CCP or OPRP as long as (safety) validation is available. So why bother if critical limits (or validatable pseudo-equivalent values) can be given ? Back to Square One. Sighhh.
Rgds / Charles.C