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PropellerPete

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Posted 26 July 2018 - 09:38 PM

Hello all,

 

I am updating a HACCP plan that someone else created, and the way they have interpreted the definitions of ccp, cp, prp, Oprp and pc are confusing me. We are currenlty certified to SQF level 2 under the old scheme and will re-certify to the food safety code Edition 8 in October. As I go through and revamp and revise, I want to make sure I am understanding correctly exactly what fits where. I have taken definitions from the FDA, the SQF code and general internet research as well as some older postings here on the topic. Here is what I think I understand:

 

CCP Any point in a specific food system where loss of control may result in a high probability of a health risk.                   CP Control Point:Any step at which biological, chemical, or physical factors can be controlled                   oPRP Essential in order to control the likelihood of introducing food safety hazards to and/or the contamination or proliferaiton of food safety hazards in the products or processing environment.                    PRP Control measures secured exclusively by preventive actions/universal procedures used to control the production environment                   Preventive Control
Those risk-based, reasonably appropriate procedures, practices and processes that a person knowledgeable about the safe manufactuing, processing, packaging or holding of food would emply to significantly minimize or prevent the hazards identified under the under the hazard analysis that are consistent with the current scientific understanding of safe food manufacturing, processing, packing or holding at the time of the analysis. 
       

I am pretty clear on what a CCP is, and what an Oprp is. But what is the technical difference between a CP and a PRP? It seems to me that a PC, PRP and CP mostly are the same thing and should all fall under the same umbrella. Additionally, some of the CPs on our current HACCP plan are really GMPs like sanitation. Is there a Venn diagram that exists somewhere that can show where and how some of these overlap? I have a decision tree, but it only lists PRP, oPRP and CCP, not preventive control or control point.

 

Thanks in advance!!



Charles.C

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Posted 27 July 2018 - 01:04 AM

Hi Propeller Pete,

 

I assume this is for Food.

You seem to have created a very unusual FS System to use for SQF.

 

I assume by "oprp" you mean "operational prerequisite program". This terminology was invented by iso for use in their haccp system (="iso-haccp") within their iso22000 FS Code.

But the haccp system within SQF8 Code is now stated to be based on Codex haccp (as a side-note, the previous SQF version 7.2 stated either Codex or NACMCF and in fact contained elements from both. However, curiously, the SQF8 Guidance has retained mention of both Codex/NACMCF. Go figure. :smile:).

 

In fact iso's "oprp" terminology is occasionally regarded as "equivalent" to NACMCF's Control Point (CP).

 

I note that you are already certified to SQF version 7.2. Did the haccp part (ie the Food Safety Plan) in yr FS Plan make use of oprp ? If so, the then SQF auditor was seemingly willing to ignore the text/Guidance of the SQF Code.

 

I suggest you have a look at SQF's detailed Guidance for SQF8 Manufacturing.

 

PS - Some "specific" definitions (mostly undefined by SQF8 afai could see) for various terms mentioned are given here - 

 

PRP - SQF8 glossary (also NACMCF)

CP - NACMCF

CCP - Codex 2003 / NACMCF

OPRP - iso22000

PC - FSMA ( ? - From a quick look, i was unable to see any official use of the acronym PC for Preventive Control ?)

 

PPS - For an expanded answer to the meaning of "CP" see this older thread (but probably still relevant) -

 

http://www.ifsqn.com...”-ccps-and-cps/


Edited by Charles.C, 28 July 2018 - 10:06 PM.
"PC" amended

Kind Regards,

 

Charles.C


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PropellerPete

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Posted 27 July 2018 - 03:00 PM

Hi Propeller Pete,

 

I assume this is for Food.

You seem to have created a very unusual FS System to use for SQF.

 

I assume by "oprp" you mean "operational prerequisite program". This terminology was invented by iso for use in their haccp system (="iso-haccp") within their iso22000 FS Code.

But the haccp system within SQF8 Code is now stated to be based on Codex haccp (as a side-note, the previous SQF version 7.2 stated either Codex or NACMCF and in fact contained elements from both. However, curiously, the SQF8 Guidance has retained mention of both Codex/NACMCF. Go figure. :smile:).

 

In fact iso's "oprp" terminology is occasionally regarded as "equivalent" to NACMCF's Control Point (CP).

 

I note that you are already certified to SQF version 7.2. Did the haccp part (ie the Food Safety Plan) in yr FS Plan make use of oprp ? If so, the then SQF auditor was seemingly willing to ignore the text/Guidance of the SQF Code.

 

I suggest you have a look at SQF's detailed Guidance for SQF8 Manufacturing.

 

PS - Some "specific" definitions (mostly undefined by SQF8 afai could see) for various terms mentioned are given here - 

 

PRP - SQF8 glossary (also NACMCF)

CP - NACMCF

CCP - Codex 2003 / NACMCF

OPRP - iso22000

PC - I suggest = (French)CP (unchecked)

 

PPS - For an expanded answer to the meaning of "CP" see this older thread (but probably still relevant) -

 

http://www.ifsqn.com...”-ccps-and-cps/

 That explains a bit more. I am working with the previous practitioner's HACCP schematic and I think he didn't realize maybe that SQF and ISO aren't meant to mesh, and in fact I think he made those changes after our last audit so an auditor may have never seen them. I am confused by your explanation of preventive control(CP), especially because that's the one I didn't think I had wrong! So, I am in America and governed by the FDA, of which the FSMA is an part. My definition of PC came straight from their website. I think my struggle is that I am trying to create one document to satisfy the requirements of both SQF and the FDA, and their terminology is just different.  Thank you for your help!



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Posted 28 July 2018 - 12:54 AM

FSMA is regulatory. You have to DO THAT.  So what they require should be at the front.

I'm BRC, not SQF, but the BRC standards require adherence to CODEX HACCP, although the standard also says you have to adhere to regulatory standards.

 

I'd recommend jettisoning any ISO stuff and blend FSMA with any other SQF requirements.

 

Marshall



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EvanAUS

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Posted 28 July 2018 - 11:02 PM

The terminology PRP and oPRP was introduced by ISO22000:2005. In my opinion it makes a useful differentiation between the control mechanisms for different types of significant hazards identified through your Hazard Analysis.
PRPs are preventative controls applied before inputs enter your process, e.g. MRL verification testing.
CCPs by definition are hazards that can vary in your process and must be monitored in real time so that you know each time that you exceed critical limits in order the apply corrective actions.
OPRPs are one-off controls within your process to control significant hazards that cannot vary in process, e.g. allergen swabs after an allergen clean before proceeding with a product that does not contain the allergen.
I hope this helps.


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Charles.C

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Posted 29 July 2018 - 05:00 AM

The terminology PRP and oPRP was introduced by ISO22000:2005. In my opinion it makes a useful differentiation between the control mechanisms for different types of significant hazards identified through your Hazard Analysis.
PRPs are preventative controls applied before inputs enter your process, e.g. MRL verification testing.
CCPs by definition are hazards that can vary in your process and must be monitored in real time so that you know each time that you exceed critical limits in order the apply corrective actions.
OPRPs are one-off controls within your process to control significant hazards that cannot vary in process, e.g. allergen swabs after an allergen clean before proceeding with a product that does not contain the allergen.
I hope this helps.


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Hi EvanAUS,

 

Thks for interesting definitions. ex CSIRO ?

 

Actually "PRP" pre-dates iso22000. It seems to have started popping-up around 2000 particularly following the NACMCF discussion of Prerequisite Programs (but not using "PRP") ca 1997. The scope of PRPs seems to have continuously evolved, ie expanded, ever since.


Kind Regards,

 

Charles.C


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Posted 31 July 2018 - 07:42 PM

Canada has had PRPs via the FSEP manual since 1993 in varying forms!

 

So it's astounding to me how many folks get confused.....to me any GFSI is a PRP program.......that plus regulartory of course 

 

Pre

REQUISITE  (a thing that is necessary for the achievement of a specified end)

Programs


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EvanAUS

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Posted 31 July 2018 - 07:52 PM

Of course - PRPs are integral control mechanisms for all food safety management systems. I think ISO22000 first formalised the terminology. Let’s not argue semantics and get off track. The OP wanted to understand the difference between CCP / PRP / oPRP.
No confusion here.


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Charles.C

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Posted 31 July 2018 - 08:27 PM

Of course - PRPs are integral control mechanisms for all food safety management systems. I think ISO22000 first formalised the terminology. Let’s not argue semantics and get off track. The OP wanted to understand the difference between CCP / PRP / oPRP.
No confusion here.


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Hi Evan,

 

If you have no confusion over OPRP, then I sincerely congratulate you. :thumbup:


Kind Regards,

 

Charles.C


EvanAUS

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Posted 31 July 2018 - 09:16 PM

I think it’s pretty clear: PRPs, oPRPs and CCPs control identified significant hazards/risks.

PRPs control hazards outside the process, e.g. pest control, approved supplier program.

oPRPs are one-off controls of hazards that do not vary, within the process, e.g. ATP swabs and/or allergen swabs to verify cleanliness before starting the process.

CCPs are monitored to control hazards that can vary in the process, e.g. time/temperature of a thermal process.



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Charles.C

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Posted 31 July 2018 - 11:59 PM

I think it’s pretty clear: PRPs, oPRPs and CCPs control identified significant hazards/risks.

PRPs control hazards outside the process, e.g. pest control, approved supplier program.

oPRPs are one-off controls of hazards that do not vary, within the process, e.g. ATP swabs and/or allergen swabs to verify cleanliness before starting the process.

CCPs are monitored to control hazards that can vary in the process, e.g. time/temperature of a thermal process.



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Hi Evan,

 

I think the Australian edition of iso22000 must be significantly different to mine.

 

Thanks anyway.


Kind Regards,

 

Charles.C


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Posted 01 August 2018 - 01:44 AM

For me, I would state that PRP are the programs that you need first to lay in your facility or system before you proceed with you HACCP study as the term prerequiste implies, if this not set firts, then all process step to manufacture producture would then be assessed as with significant hazard. This to be synonymous with GMP (if you are more familiar with that term).

 

oPRPs and CCPs are more line specific. The difference would then be on how you decide this in your decision tree.  In my experience, to simplify this, we have the difference of measurable limit and the time to react in case of deviations for CCPs.

 

CPs we then define as points in the manufacturing line we need to ensure we have monitored and recorded daily to ensure consistency of quality what we produce.



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Posted 01 August 2018 - 08:33 AM

Hi Evan,

I think the Australian edition of iso22000 must be significantly different to mine.

Thanks anyway.

Hi Charles,
The ISO22000 Standard is an international standard - yours is the same version as mine, written in English (admittedly comprehension varies). It may be that my understanding has evolved because I audit FSSC22000, BRC and SQF, but this is a widely accepted (in Australia - can’t speak for the rest of the world) interpretation of the terminology used in the ISO22000 Standard.

I think the difference between PCs and CPs should be a separate discussion.


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Charles.C

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Posted 02 August 2018 - 04:16 AM

Of course - PRPs are integral control mechanisms for all food safety management systems. I think ISO22000 first formalised the terminology. Let’s not argue semantics and get off track. The OP wanted to understand the difference between CCP / PRP / oPRP.
No confusion here.

(q1) I think it’s pretty clear: PRPs, oPRPs and CCPs control identified significant hazards/risks.

(q2) PRPs control hazards outside the process, e.g. pest control, approved supplier program.

(q3) oPRPs are one-off controls of hazards that do not vary, within the process, e.g. ATP swabs and/or allergen swabs to verify cleanliness before starting the process.

(q4) CCPs are monitored to control hazards that can vary in the process, e.g. time/temperature of a thermal process.
 

Hi Charles,
The ISO22000 Standard is an international standard - yours is the same version as mine, written in English (admittedly comprehension varies). It may be that my understanding has evolved because I audit FSSC22000, BRC and SQF, but this is a widely accepted (in Australia - can’t speak for the rest of the world) interpretation of the terminology used in the ISO22000 Standard.

I think the difference between PCs and CPs should be a separate discussion.

 

Hi Evan,

 

A few comments.

 

Semantics - the meaning of a word, phrase, sentence, or text.

Evolve - develop gradually, especially from a simple to a more complex form. Synonyms: develop, progress, advance.

 

IMO semantics can matter. Especially where (IMO) a  highly confused topic such as in this thread is concerned.

With respect to (q1-4) above I believe it matters particularly for the terms PRP, OPRP, significant, Process.

 

In the context of (q1-4), I interpret "Process" as the operational process given in the Scope for the HACCP Plan.

 

ISO22000 (2018)(=”iso2”) has IMO introduced some clarity to the (2005) version. (And some further confusions which I won't discuss here).

 

I am not aware of any official iso statements but I suspect that portions of the 2nd (2014) version of iso22004, had foreknowledge of some of the likely changes in iso2. (Both revisions sure took long enough to cogitate over !)

 

Regarding “clarity” there are some new/modified definitions-requirements in iso2, eg –

 

(a)

Significant food safety hazard - food safety hazard  identified through the hazard assessment, which needs to be controlled by  control measures.

 

NB - iso22004 has an expanded version -

Significant hazard - biological,  chemical  or  physical  hazard,  identified  through  the  hazard  analysis  process,  which  needs  to be controlled at critical control point(s) [CCP(s)], or by operational PRP(s) and/or by combinations  thereof.

 

(b)

Operational prerequisite programme (OPRP) - control measure or combination of control measures applied to prevent or reduce a  significant food safety hazard  to an  acceptable level  and where  action criterion  and  measurement  or observation enable effective control of the  process  and/or  product.

(c)

Prerequisite programme (PRP) - PRP basic  conditions  and  activities  that  are  necessary  within  the  organization  and  throughout  the  food chain  to maintain food safety.

The PRPs needed depend on the segment of the food chain in which the organization operates  and the type of organization. Examples of equivalent terms are: good agricultural practice (GAP), good veterinary  practice  (GVP),  good  manufacturing  practice  (GMP),  good  hygiene  practice  (GHP),  good  production  practice  (GPP), good distribution practice (GDP) and good trading practice (GTP).

 

(d)

8.2.4  When establishing PRP(s) the organization shall consider:

 

a)    construction, lay-out of buildings and associated utilities;

b)    lay-out of premises, including zoning, workspace and employee facilities;

c)     supplies of air, water, energy and other utilities;

d)    pest control, waste and sewage disposal and supporting services;

e)    the suitability of equipment and its accessibility for cleaning and maintenance;

f)     supplier  approval   and   assurance  processes  (e.g.  raw   materials,   ingredients,   chemicals  and  packaging);

g)    reception of incoming materials, storage, dispatch, transportation and handling of products;

h)    measures for the prevention of cross contamination;

i)     cleaning and disinfecting;

j)     personal hygiene;

k)    product information/consumer awareness;

l)     others, as appropriate.

 

 

I also enclose a snippet from iso22004 (2014) –

(e)

Attached File  relationship for PRPs, CCPs, OPRPs.png   126.69KB   5 downloads

 

(f)

Verification - confirmation, through the provision of objective evidence, that specified  requirements have been  fulfilled.

---------------------------------------------------------------------------------------------------------

 

Regarding (q1-4), the quotes (a-f) suggest some possible conflicts with iso22000, eg  –

 

(q1) :  (i) PRP Chronology (see e), (ii) “PRPs control significant hazards” (see e,c,a)

(q2) :  (i) “PRPs control hazards outside the process” (see c,d,e)

(q3) :  (i) “ OPRP ……e.g. ATP swabs and/or allergen swabs to verify cleanliness before starting the process.” (see f)
 

So Yes, if (1-4) is representative, I think the Australian interpretation may be rather “special”.  Whether it has evolved....?.


Kind Regards,

 

Charles.C


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Posted 10 August 2018 - 12:23 PM

Hi Pete, 

 

We recently were certified for SQF V8, and you need to be very careful on the definitions you are using since the auditors are paying very close attention to this. SQF V8 greatly expanding point 2.4.3 on Food safety plans, therefore auditors are spending more time on this point. It should also be noted that SQF V8 requires your HACCP plan be developed using Codex, but you need to ensure you are meeting all your regulatory requirements as well (they slipped this to ensure some consistency with FSMA requirements). 

 

Our company is also subject to FSMA as we ship to the US, therefore we created our HACCP Plan using Codex principles, but added on the notions of preventive controls. This may not work in every case (depending on the complexity of your process), but it is definitely clearer and simpler to have one plan rather than multiples. If you are subject to FSMA, be sure to include preventive controls somewhere in your plan since the auditor will check for this. 

 

For the definitions outlined above, I would simply eliminate some of them since quite frankly overlap and may lead to confusion for your auditor. SQF works win the following format - GMPs applied through your Pre-requisite programs (Module 3-12, depending on your FSC), and your Food Safety plan (CCP, CP and preventive controls if you are subject to FSMA). I would therefore suggest to you to only define pre-requisite program, CCP, CP and preventive controls. 

 

Your initial definition for preventive controls is correct (it is directly pulled from the PC rule), but I would work on re-phrasing your other definitions:

- CP: A point in the process where a hazard can be reduced but not eliminated, and a subsequent step will eliminate the hazard 

- CCP: A point in the process where a control measure can be applied and a  hazard can be prevented, eliminated or reduced to an acceptable level

- PRP: Program of procedures implemented to assist in controlling the likelihood of introducing hazards through the work environment or operational practices. 



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PropellerPete

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Posted 10 August 2018 - 02:42 PM

Hi Pete, 

 

We recently were certified for SQF V8, and you need to be very careful on the definitions you are using since the auditors are paying very close attention to this. SQF V8 greatly expanding point 2.4.3 on Food safety plans, therefore auditors are spending more time on this point. It should also be noted that SQF V8 requires your HACCP plan be developed using Codex, but you need to ensure you are meeting all your regulatory requirements as well (they slipped this to ensure some consistency with FSMA requirements). 

 

Our company is also subject to FSMA as we ship to the US, therefore we created our HACCP Plan using Codex principles, but added on the notions of preventive controls. This may not work in every case (depending on the complexity of your process), but it is definitely clearer and simpler to have one plan rather than multiples. If you are subject to FSMA, be sure to include preventive controls somewhere in your plan since the auditor will check for this. 

 

For the definitions outlined above, I would simply eliminate some of them since quite frankly overlap and may lead to confusion for your auditor. SQF works win the following format - GMPs applied through your Pre-requisite programs (Module 3-12, depending on your FSC), and your Food Safety plan (CCP, CP and preventive controls if you are subject to FSMA). I would therefore suggest to you to only define pre-requisite program, CCP, CP and preventive controls. 

 

Your initial definition for preventive controls is correct (it is directly pulled from the PC rule), but I would work on re-phrasing your other definitions:

- CP: A point in the process where a hazard can be reduced but not eliminated, and a subsequent step will eliminate the hazard 

- CCP: A point in the process where a control measure can be applied and a  hazard can be prevented, eliminated or reduced to an acceptable level

- PRP: Program of procedures implemented to assist in controlling the likelihood of introducing hazards through the work environment or operational practices. 

Thank you so much AudreyB! This will be our 3rd time certifying, but my personal first, and I have had to completely re-do all our HACCP and associated docs from the ground up. I appreciate it :) 



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Posted 30 July 2020 - 12:14 AM

PRP - basic conditions and activities that are necessary within the organization and throughout the food chain to maintain food safety.

CP - step in the process at which control measures are applied to prevent or reduce a significant food safety hazard to an acceptable level, and defined critical limits and measurements enable the application of occurrence.

The difference is that CP relates specifically to a step in the process, and not a general activity or action. I would also recommend installing an antivirus and optimization software to maintain the safety of the computers and to keep them optimized. Before choosing an optimization software, I would recommend reading this article from xxxxxxx. It is well structured, full of information and important details and it was written by the chief editor of think mobiles, a renowned company that conducts IT & software reviews since 2011.


Edited by Charles.C, 30 July 2020 - 01:35 AM.
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