16 replies to this topic

[dt2win]

Hii,

 

We are working for SQF Code-Module 2 and Module 11.

 

Module 2 , Section 2.4.2 Food Safety Fundamentals requires to maintain the pre-requisite programs.

 

Can I consider the topics mentioned in Module 11 as our PRPs or do I have make a separate file for PRPs.

 

Bit confused.Please help

 

Thanks in advance

 

DT

[Setanta]

No, you should make a separate list of all of your PRP.  It safes the auditor hunting for them and I believe there is specific language requiring it, but I can't remember where.  We almost got a ding for this, but I had a list in another spot that covered me.

 

Setanta

[dt2win]

Thanks Setanta.

 

One thing more. 

Is there any list of PRPs for food safety mentioned in the SQF code?

 

If not, I have to define PRPs according to my company processes and requirements.

 

Regards

DT

[SpursGirl]

I also have a seperate list of all my PRP's and also have a reference list to procedures/policys that control the PRP

 

S

[dt2win]

Can you please provide me example for list of PRPs?

 

It would be a great help.

[Setanta]

Well, I don't know what you product, but here are some general programs...

Personnel Practices (GMPs)
Personnel Processing Practices
Training of Personnel
Calibration of Equipment
Management of Pests and Vermin
Monitoring Water Microbiology
Control of Physical Contaminants

[Charles.C]

Dear d2win,

 

The basic sqf-related answer to yr (list) query (not myself a sqf user) seems to be -

 

SQF Glossary - Prerequisite

A procedural measure that when implemented reduces the likelihood of a food safety hazard or a food quality threat occurring, but one that may not be directly related to activities taking place during production.

 

 

 

2.4.2.3

Those pre-requisite programs applicable to the scope of certification that outline the means by which food safety is controlled and assured shall be documented and implemented.

 

 

The above naturally relates to your product / process / haccp / local legislation (maybe) in addition to GMP basics.

 

One famous basic US set is, I think, the "Big 8" (not the allergen one).

added later - see -

http://www.fao.org/d...3e/y4743e0h.htm

 

From memory there is also (somewhere) a classic US publication comparing typical PRP lists for USFDA/FSIS/Codex et al. Probably somewhat out-of-date but maybe useful.

 

added later - see -

 HACCPPrerequesites.pdf   32.57KB   604 downloads

 

An obvious "minimum" requirement is the list will need to comply with the relevant text of sections 11.1 - 11.10.

 

Looks like some study of the Code is indicated.

 

Rgds / Charles.C

[SpursGirl]

This is the list of PRP's I have in my facility - has passed 3 SQF audits - hope that helps!

 

PRP List

Attached Files

•  7.004 Pre-requisite Program.docx   27.41KB   713 downloads

[Charles.C]

Dear Spurs Girl,

 

Thks for the attachment.

 

Yr list contains a few categories which I personally find rather strange to be listed as PRPs, eg -

Calibration

Traceability

Finished Product Controls

 

However i agree that the above can be made to fit the SQF definition quoted earlier, ie -

 

A procedural measure that when implemented reduces the likelihood of a food safety hazard or a food quality threat occurring, but one that may not be directly related to activities taking place during production.

 

The original PRP concept (eg Codex) was/is, i think, more or less directly focused on maintenance of satisfactory factory hygiene.  The primary Codex document makes no mention of the above 3 items. SQF/BRC both reference the Codex principles as the basis for their HACCP systems.

 

It appears that SQF and BRC have phrased their definitions (use of "may" and "operational" respectively)  to  include almost any procedures as required.

 

The ISO list (ISO 22002-1) of prerequisite programs does not include the above 3 items although ISO 22000 could via an appended Note to its "hygienic" definition..

 

From a purely HACCP POV (which afaik is the reason for using PRPs), the unlimited expansion seems a negative step to me.

 

I guess you pays yr money and .....

 

Rgds / Charles.C

[SpursGirl]

Hi Charles,

 

I agree the 3 PRPs are a bit unusual however I have these additional PRP's for level 3 SQF where the HACCP plan includes quality CCPs/PRP's.

 

Calibration is in place for mainly scales (weights of components so that product meets specificaiton/declared quid) and thermometers for cook attributes (hitting caramelization temperatures etc).

 

Traceability to ensure we are using materials within date code and that we are traceable back to COA (making sure materials meet quality standards).

 

Finished product controls to ensure that the product meets specification on quality attributes (appearance, taste, texture blah blah blah)

 

With Level 3 SQF (well SQF in general tbh) I find that the more directly you document controls the easier it goes in the audit, if the auditor can see a document that spells things out it generally leads to a tick in the box 

 

S

[ChrisO001]

I'd be interested in hearing what other members list as PRPs. We list the following in our food safety and quality manual (thinking we may be overboard):

1. Personnel Practices
2. Personnel Processing practices
3. Training of Personnel
4. Calibration of Equipment
5. Management of Pests and Vermin
6. Premises and Equipment Maintenance
7. Cleaning and Sanitation
8. Monitoring Water Microbiology and Quality
9. Control of Physical Contaminants
10. Supplier Approval
11. Transport and Delivery
12. Waste Management and Disposal
13. Allergen Control
14. Environmental Pathogen Monitoring.

[Setanta]

Ours has 12, I think we don't list environmental pathogen, but we do it and transport isn't listed as a PRP.

[dt2win]

Dear Chris001,

 

 

The PRPs which you have mentioned were shown separate in SQF 2000 Code-Ed 6.But in Edition 7,these are merged with other GMPs in Module 11(we are following Module 11 for our Product).The confusion arises here if they are already in Module 11 and we have to document them so why a separate set of PRPs is required to document.

 

Hope you got my point.

 

Thanks

[mduane]

I love the irony, I actually have been working on 2.4.2 all day today trying to refine what to include as a PRP!

 

I think I have decided to use the following 13 PRPs these are also the 13 things that are covered under our 2.5 Verification and Validation Program. If it is a PRP, it needs to be big and important and can have sub-categories. Our 13 are as follows:

 

1. GMP Personnel Practices

2. Processing Practices

3. Training

4. Calibration

5. Pest Control

6. Maintenance

7. Sanitation

8. Foreign Material

9. Environmental Monitoring

10. HACCP Plan / CCP Control

11. Waste Management

12. Allergen Control

13. Customer Complaints

 

As a part of 2.5 Verification and Validation these are also areas that require some trending analysis. 

 

Any feedback on my comment are welcome, and appreciated!

[ncwingnut]

We have all the programs listed in module 11, PLUS more.  We have 48 PRPs altogether, and 98 forms that go along with them.  When we were setting up for SQF 3 years ago, we did a lot of over-thinking.

 

Since we just passed our recert the beginning of June, I'm spending the next 10 months consolidating them.  48 is just too much to handle.

[Tony-C]

I think that the SQF Code confuses a little by quoting Food Safety Fundamentals, Good Manufacturing Practices (GMPs) and Pre-requisite Programs.

Pre-requisite Programs Defintion - A procedural measure that when implemented reduces the likelihood of a food safety hazard or a food quality threat occurring, but one that may not be directly related to activities taking place during production.

 

So you could end up with a list that looks something like this:

 

QM 2.3.1 Product Development
QM 2.3.2 Raw and Packaging Materials
QM 2.3.3 Contract Services
QM 2.4.1 Customer, Statutory and Regulatory Conformance
QM 2.4.5 Control of Purchased Materials and Services
QM 2.4.5 Verification of Purchased Materials and Services
QM 2.4.6 Control of Non-Conforming Product or Equipment
QM 2.4.8 Product Release
QM 2.4.9 Stock Control
QM 2.6.1 Product Identification
QM 2.8.2 Allergen Management
QM 2.9 Training
QM 11.1 Site Requirements and Approval
QM 11.2 Construction and Control of Product Handling and Storage Areas
QM 11.2.9 Premises and Equipment Maintenance
QM 11.2.10 Calibration
QM 11.2.11 Management of Pests and Vermin
QM 11.2.12 Equipment, Utensils and Protective Clothing
QM 11.2.13 Cleaning and Sanitation
QM 11.3 Personnel Hygiene and Welfare
QM 11.3.2 Handwashing
QM 11.3.3 Clothing
QM 11.3.4 Jewellery Policy
QM 11.3.5 Control of Visitors and Contractors
QM 11.3.6 Staff Amenities
QM 11.3.6 - 9 Staff Facilities
QM 11.3.11 First Aid
QM 11.4 Hygiene Code of Practice
QM 11.5 Water and Ice Supply
QM 11.5.2 Monitoring Water Microbiology and Quality
QM 11.5.7 Air Quality
QM 11.6 Storage and Transport
QM 11.6.6 Loading, Transport and Unloading Practices
QM 11.7 Control of Operations
QM 11.7.5 A Glass Policy
QM 11.7.5 B Control of Brittle Materials
QM 11.7.5 C Glass & Brittle Material Breakage Procedure
QM 11.7.5 Control of Foreign Matter Contamination
QM 11.7.6 Detection of Foreign Objects
QM 11.8 On-Site Laboratories
QM 11.9 Waste Disposal
QM 11.10 Exterior

 

Or you could condense/combine your programs.

 

Regards,

 

Tony

[R. U. Cereus]

A couple of years ago, I found the following buried under the "Guidance" column of the SQF Code Ed. 7 Audit Checklist, in section 2.4.2.2 It wasn't included anymore for Code Ed. 7.2, but it is still applicable.

You can find this document here http://www.sqfi.com/documents/

 

Required pre-requisite programs:

Personnel Practices, Personnel Processing Practices, Training of Personnel, Calibration of Equipment, Management of Pests and Vermin, Premises and Equipment Maintenance, Cleaning and Sanitation, Monitoring Water Microbiology and Quality, Control of Physical Contaminants, Supplier Approval, Transport and Delivery, Waste Management and Disposal, Allergen Control