3 replies to this topic

[AGomez]

Hi everyone!

 

This is the second time I have inquired about PRP's; I dropped it for a while out of frustration but here I am again. I am working on PRP's for my facility. We are a co-packer of sugars, spices, drink mixes, etc. There is no temperature control; all ambient. Well, my question is what exactly goes into PRP's? Right now it feels like I'm just reiterating and summarizing all our policies, procedures, and work instructions. Is that what it is? If so, if we are already validating/monitoring all our procedures and policies, do we have to validate/monitor them again? It just seems like I am reiterating everything we have and doubling my work. Please Help!!!

[Charles.C]

Hi everyone!

 

This is the second time I have inquired about PRP's; I dropped it for a while out of frustration but here I am again. I am working on PRP's for my facility. We are a co-packer of sugars, spices, drink mixes, etc. There is no temperature control; all ambient. Well, my question is what exactly goes into PRP's? Right now it feels like I'm just reiterating and summarizing all our policies, procedures, and work instructions. Is that what it is? If so, if we are already validating/monitoring all our procedures and policies, do we have to validate/monitor them again? It just seems like I am reiterating everything we have and doubling my work. Please Help!!!

 

Hi AG,

 

JFI here are the previous related threads -

 

http://www.ifsqn.com...isite-programs/

http://www.ifsqn.com...2-prps-vs-sops/

 

As i understood, you were previously producing PRPs primarily for FDA audit purposes (post 14). Seems like now for BRC also ?

 

IMHO the simplest solution would be for you to use a format similar to those already existing in the "literature".

 

However i am unsure whether FDA and BRC have the same requirements. Do you have any priority ?

[AGomez]

My priority is BRC. Although we fall under FDA inspections, we've never had any since I've been here.

[Charles.C]

Hi AGomez,

 

I have put something together for you to study.

 

The exact format for PRPs is up to you. Different users have their own preferences.

The PRP contents will be expected to minimally cover the requirements of BRC Clause 2.2 and other references in the standard, eg 2.12.1, 2.14.1, 3.4.1, 4.3.1, etc

 

Below are example of four sets of PRPs of varying style. ( Allergen PRP  is absent, 1-2 examples are available on the Forum)

 

(1)

 SSOP Plan - Sanitation Control Records.pdf   1.48MB   146 downloads

(Pgs 1-16)

 

(2)

http://www.ifsqn.com...le/#entry101966

(Vol2 - Pgs 61-86)

 

(3)

http://www.ifsqn.com...es/#entry102564

(Pgs 8-48)

 

(4)

http://www.ifsqn.com...mpany/#entry220

(See “hygiene management system” file in zip folder).

 

IMO No.4  (BRC Packaging, ca 2003) has the best Procedural layout from a logic/clarity POV particularly via the use of  cross-referencing. I have used a similar style for BRC Food. The presentation shown maybe calls for some expansion of the text but was (2003) acceptable for audit purposes.

No.1  is a completely worked out SSOP system. (the various  activities in the cleaning PRP  are often combined into a  master program). Can compare the text with No.4. This layout was designed to comply  with FDA Final Seafood Rule ca 1995.

No.2 uses a more tabular format and clarifies the various  components which should be included. The aspect of  “control measure” is a particular key factor.

No.3 (CFIA) is highly textual/prescriptive. The content/requirements are well-spelled out but the document comes over (to me)  as rather “wordy”.

 

I suggest you initially compare the above to yr existing hygiene setup for compatibility.

 

Note that most of the above are quite old so may lack responses to some specific BRC Clauses. For example here is a  more recent Pest Control Program -

 Pest Control Program.pdf   275.83KB   107 downloads