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Removal of foreigh bodies with sieve - from CCP to OPRP

foreign body ccp oprp ISO22000

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#1 Anf

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Posted 05 November 2018 - 12:05 PM

Hi all,

 

In ISO 22000:2018 there is a new definition on CCP:

- step in the process at which control measure is applied to prevent or reduce a significant food safety hazard to an acceptable level and defined critical limit and measurement enable the application of correction.

 

An FSSC auditor I talked to meant that this means that a sieve to prevent foreign bodies in end product now is no longer a CCP, but an OPRP.

 

Today our critical limit is "sieve whole/sieve broken".

 

The new definition includes measurement (process to determine a value), which is not included in our CCP.

 

I guess we're not the only FSSC certified company using sieves to prevent foreign bodies. What have you other guys done? Are your sieves now an OPRP?

 

 



#2 Abd El-Rahman

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Posted 05 November 2018 - 01:41 PM

how?

i wheat milles

foreign bodies important for flour 

plastic for example at end product.



#3 Anf

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Posted 05 November 2018 - 07:52 PM

 

 

Foreign bodies are important, the question is if it by the new ISO22000 standard should be classified as an OPRP and not a CCP when using a sieve to remove them.



#4 012117

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Posted 05 November 2018 - 11:43 PM

Hi, Anf.

 

If you go on key description of CCP (based on ISO 22000), it should be measurable and you can react immediately once there is a problem with your control measure. In the case of sieve, limit can be size of the mesh, however, it is not enough as the limit should also be that it is of correct fit and intact to ensure all products will be passing thru.

On the 2nd definition, in example you run for 16 hours and got to inspect sieve every 16 hours only, and say you have problem in the 2nd hour, then your reaction will be delayed by 14 hours.

 

In terms of definition of CCP, it says eliminate or reduce to an acceptable level. For oPRP, you control the likelihood of introducing hazard. If in any instance, for example, you have a 10 mm wire (US FDA 7mm, CFIA 2mm as limit for physical hazard) than pass thru perpendicular to your sieve opening, did the sieve eliminated or reduce the hazard to an acceptable level? If this happen, will you say your CCP is not effective?

 

 

Given the description above,depending on your decision tree, you may categorize it as CCP or oPRP, but have reality check after your categorization using the above scenario :)


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#5 Charles.C

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Posted 06 November 2018 - 02:32 AM

Hi all,

 

In ISO 22000:2018 there is a new definition on CCP:

- step in the process at which control measure is applied to prevent or reduce a significant food safety hazard to an acceptable level and defined critical limit and measurement enable the application of correction.

 

An FSSC auditor I talked to meant that this means that a sieve to prevent foreign bodies in end product now is no longer a CCP, but an OPRP.

 

Today our critical limit is "sieve whole/sieve broken".

 

The new definition includes measurement (process to determine a value), which is not included in our CCP.

 

I guess we're not the only FSSC certified company using sieves to prevent foreign bodies. What have you other guys done? Are your sieves now an OPRP?

 

Hi Anf,

 

With all due respect i do not see anything particularly new in this definition ? Seems merely to provide a restatement of the Codex original by inserting the (implied) definition of a "significant hazard", ie -

 

significant  food safety hazard - food safety hazard (3.22), identified through the hazard assessment, which needs to be controlled by control measures (3.8)

 

IMO a crucial word in the above def. is "needs". It is maybe regrettable that its equivalent word in the Codex definition has now been relegated to a secondary level.

 

People have been arguing for years over whether the control measure mentioned in OP should be associated with a PRP, CCP, OPRP. With no consensus in sight. The critical limit  referred has also been in the haccp Literature for a considerable time.

 

Seems to me you can use any of the three options above provided you can validate your decision. Whether an auditor will agree with yr validation  is a different question.


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Kind Regards,

 

Charles.C


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#6 Anf

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Posted 06 November 2018 - 07:10 AM

Thank you both for your responses to my question. I will keep the sieves as CCPs during our upcoming FSSC audit later this month. You gave me a reasonable arguments I can use if the auditor questions why.


#7 Philip Jones

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Posted 13 November 2018 - 10:29 PM

Whichever you do, your control methods and reactions are likely to be the same.  I personally agree with the oPRP definition, but at the end of the day, it is your HACCP plan and your decision tree.  No decision tree is perfect, but the one you are using is (hopefully) the one the HACCP team have agreed as giving the appropriate level of food safety for your factory.  If the auditor wants to change it, ask him if there is an incident and the HACCP is going to be challenged in court, will he come and explain why he felt it necessary that you change it on his instruction.  I have had retailer auditors try that and they soon back off.



#8 Abd El-Rahman

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Posted 14 November 2018 - 07:21 AM

can we use Q in decision tree if this point treat by PRP ?



#9 012117

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Posted 14 November 2018 - 08:26 AM

Hi, Abd.

 

It will depend on what is in your decision tree. However, by logic, if the sieve is determined to control the identified significant physical hazard, and there would be no subsequent step based on your manufacturing step, I think it is hard to justify that it is only managed by PRP. You may need to review your decision tree or how you went about with the decision.



#10 Charles.C

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Posted 15 November 2018 - 06:53 PM

Hi, Abd.

 

It will depend on what is in your decision tree. However, by logic, if the sieve is determined to control the identified significant physical hazard, and there would be no subsequent step based on your manufacturing step, I think it is hard to justify that it is only managed by PRP. You may need to review your decision tree or how you went about with the decision.

 

Hi 012,

 

Actually not so hard.

 

Example attachment here -

 

https://www.ifsqn.co...ed/#entry130975

 

OPRP is another ball-game of course.


Kind Regards,

 

Charles.C


#11 012117

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Posted 15 November 2018 - 11:20 PM

Hi, Charles.

 

I understand. But as per my previous post, key is "significant" based on the assessment which I mean even with the implementation of PRPs (considering good enough), the hazard is still significant. Thanks for sharing though, I sometimes wonder, if you remember all the topics as you can can provide links with almost all on the forum  :rock: 

 

Thanks. 







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