41 replies to this topic

[Charles.C]

Hi Lyon.Lim,

 

The problem with OPRP was that it evolved over several phases ending up completely different to its original intentions. And it still keeps evolving.

 

It ultimately depends on what is auditorially acceptable. Preferably IMO requiring the minimum amount of cogitation.

 

If you refer to the Tree (Procert) issued by one of the "designers" of the iso22000:2005 version, it is predicated on keeping things "simple" as far as possible.

 

TBH the more involved the Standard gets, I now think that the tabular format makes life easier.

 

After all, the iso basic concept (ISO22004) is that the designation between CCP and OPRP is not so important as long as the significant hazards are controlled.

[Lyon.Lin]

Hi Lyon.Lim,

 

The problem with OPRP was that it evolved over several phases ending up completely different to its original intentions. And it still keeps evolving.

 

It ultimately depends on what is auditorially acceptable. Preferably IMO requiring the minimum amount of cogitation.

 

If you refer to the Tree (Procert) issued by one of the "designers" of the iso22000:2005 version, it is predicated on keeping things "simple" as far as possible.

 

TBH the more involved the Standard gets, I now think that the tabular format makes life easier.

 

After all, the iso basic concept (ISO22004) is that the designation between CCP and OPRP is not so important as long as the significant hazards are controlled.

 

That's true for meaningless discussion on the OPRPs and the CCP for the company. 

 

As a lead auditor, I still need to try my best to provide high-quality audit activity, precision for interpretation of the clause is a big challenge, although we always know that our client won't care about that after the ISO 22000 audit.

[Charles.C]

That's true for meaningless discussion on the OPRPs and the CCP for the company. 

 

As a lead auditor, I still need to try my best to provide high-quality audit activity, precision for interpretation of the clause is a big challenge, although we always know that our client won't care about that after the ISO 22000 audit.

 

Sorry you consider it a meaningless discussion.

 

But thanks anyway.

[Lyon.Lin]

Sorry you consider it a meaningless discussion.

 

But thanks anyway.

 

Sorry, I mean "After all, the iso basic concept (ISO22004) is that the designation between CCP and OPRP is not so important as long as the significant hazards are controlled."

 

It just holds a lot of time for discussion if our client has already controlled significant hazards pretty well.

 

Sometimes the great knowledge can only be inherited by the few people.

 

And you did a good job. 

 

Anyway, if the OPRP and CCP be separate precisely, the control will be more systematically and clearly.

 

Thank you for the advice on this topic.

[Charles.C]

JFI here is a compilation (few years back) of 13 snapshots of various methodologies to distinguish CCP/OPRP in the context of iso22000:2005. All, I think, previously posted on this Forum. (There are many more on the IT of course).

 

 CCP-OPRP decision methods, 2.0.xls   1.53MB   276 downloads

 

PS - 3 are in French language, One in Indonesian (?)  Translations are maybe available (somewhere).

[El Molino]

I had a discussion with our auditor regarding oPRP's and the definition in ISO 22000 - however, in the CFIA FSEP programs the oPRPs are defined in section G of the PRP's. It actually take s the guesswork out and the way to handle these defined hazards. Ironically PRP's and oPRP's all have ways of controlling a defined hazard. Allergens for example are defined in the FSEP as an oPRP... with combinations of control measures and of course a defined SOP.  Metal detection can be a CCP ir oPRP depending on the customer requirements. 

There are many Codex decision trees that can be used to accommodate the oPRP's. The details are in the SOP's and "yes" can all be integrated into a HACCP plan. In fact our CFIA inspector does not want a deviation from the formal FSEP program -it makes the Preventive Controls surveillance part of his CVS tasks easier.

[Charles.C]

I had a discussion with our auditor regarding oPRP's and the definition in ISO 22000 - however, in the CFIA FSEP programs the oPRPs are defined in section G of the PRP's. It actually take s the guesswork out and the way to handle these defined hazards. Ironically PRP's and oPRP's all have ways of controlling a defined hazard. Allergens for example are defined in the FSEP as an oPRP... with combinations of control measures and of course a defined SOP.  Metal detection can be a CCP ir oPRP depending on the customer requirements. 

There are many Codex decision trees that can be used to accommodate the oPRP's. The details are in the SOP's and "yes" can all be integrated into a HACCP plan. In fact our CFIA inspector does not want a deviation from the formal FSEP program -it makes the Preventive Controls surveillance part of his CVS tasks easier.

 

Hi El Molino,

 

(Bit OT)

 

With all due respect IMO yr auditor's comments are outdated and I suspect were never exactly germane in the first place..

 

I'm unsure when the Canadian "operational prerequisite program" ("Coprp") ("oprp" does not occur in  FSEP 2014) was launched but it looks like the definition was simply "borrowed" from iso22000 and then utilised in a different way as per Canadian requirements. ( IIRC "Coprp" has a very faint similarity to iso's concept in an abandoned precursor to its published 2005 version).

 

iso22000:2018 subsequently dropped the original definition of oprp, probably a long-overdue reflection of the.incredible level of user confusion which it has engendered for 13 years.

 

There is only one Codex Decision Tree (CDT) albeit numerous proposed decision trees exist for use in iso22000 . Regarding CDT's usage in an iso22000 context, see the quotation here -

 

https://www.ifsqn.co...24/#entry159219

 

Regardless "Coprp" does seem to have at least one redeeming characteristic, it is  chronologically implemented as a PRP which iso's oprp is patently not.

 

TBH, I don't really see why CFIA originally introduced "Coprp" at all since they could have just expanded the list of PRPs. ?

[Lyon.Lin]

I had a discussion with our auditor regarding oPRP's and the definition in ISO 22000 - however, in the CFIA FSEP programs the oPRPs are defined in section G of the PRP's. It actually take s the guesswork out and the way to handle these defined hazards. Ironically PRP's and oPRP's all have ways of controlling a defined hazard. Allergens for example are defined in the FSEP as an oPRP... with combinations of control measures and of course a defined SOP.  Metal detection can be a CCP ir oPRP depending on the customer requirements. 

There are many Codex decision trees that can be used to accommodate the oPRP's. The details are in the SOP's and "yes" can all be integrated into a HACCP plan. In fact our CFIA inspector does not want a deviation from the formal FSEP program -it makes the Preventive Controls surveillance part of his CVS tasks easier.

 

For foreign metal control:

If we use a metal detector as a resource of a control measure

 

Keep metal detector still work: OPRP

Keep all products go through metal detector: CCP

 

It does not depend on the customer's requirement actually, just not easy to notice that keep all products go through the metal detector is an act of the CCP control measure.

 

Another example:

 

Raw material acceptance

 

Get COA or inspection report for each batch before manufacturing: OPRP

Raw material inspection for each batch, ok then go, otherwise not go operate next step: CCP

 

 

As for the Decision Tree to determine CCPs? You don't even need to double-check metal detect then you already know it's CCP. Why? And the "why" will be your decision tree.

[Ahsandro]

Would be really helpful if you guys could check and give feedback. I have found similar one for the old version and thought to give a try for with the new requirement. I hope i have covered all the points.

where's your reference for assessment methode to determine CCP/OPRP??

Edited by Ahsandro, 18 November 2020 - 09:13 AM.

[Charles.C]

where's your reference for assessment methode to determine CCP/OPRP??

The current methodology for iso22000:2018 is an expanded version of one developed for iso22000:2005 whose usage is illustrated here -

 

https://www.ifsqn.co...ge-4#entry51985

 

The above scheme is based on a layout posted on this forum and referenced within the excel. Similar schemes were independently posted on the Internet around 10-15 years ago.

 

Note that an alternative, non-numerical, approach is described in post 24 of this current thread which is based on a slightly expanded version of the well-known Coca-Cola tree also launched for iso22000:2005. (I didn't have time to draw the expanded layout).

 

The specific levels used in all these decision trees (and any weighting factors if used) are of course arbitrary, just like haccp likelihood/severity matrices.

 

Note that fssc have also issued a method for categorising  OPRPs which I found unsatisfactory for reasons detailed elsewhere on this Forum.

Edited by Charles.C, 18 November 2020 - 10:04 AM.
edited

[Ahsandro]

The current methodology for iso22000:2018 is an expanded version of one developed for iso22000:2005 whose usage is illustrated here -

 

https://www.ifsqn.co...ge-4#entry51985

 

The above scheme is based on a layout posted on this forum and referenced within the excel. Similar schemes were independently posted on the Internet around 10-15 years ago.

 

Note that an alternative, non-numerical, approach is described in post 24 of this current thread which is based on a slightly expanded version of the well-known Coca-Cola tree also launched for iso22000:2005. (I didn't have time to draw the expanded layout).

 

The specific levels used in all these decision trees (and any weighting factors if used) are of course arbitrary, just like haccp likelihood/severity matrices.

 

Note that fssc have also issued a method for categorising  OPRPs which I found unsatisfactory for reasons detailed elsewhere on this Forum.

your document which is be attached, is it still valid to be implemented to determine CCP/OPRP ISO 22000:2018??, so I ask you about reference. I only know decison tree's reference from codex and FSSC interpretation
 

[Charles.C]

your document which is be attached, is it still valid to be implemented to determine CCP/OPRP ISO 22000:2018??, so I ask you about reference. I only know decison tree's reference from codex and FSSC interpretation
 

The document referred is a suggested interpretation for iso22000:2018. If you google, you can find many others.

 

Note this comment in FSSC's publication -

 

 comment.pdf   29.54KB   97 downloads

[Lyon.Lin]

your document which is be attached, is it still valid to be implemented to determine CCP/OPRP ISO 22000:2018??, so I ask you about reference. I only know decison tree's reference from codex and FSSC interpretation
 

Hi, Ahsandro:

I think need to remind you that the difference between the V2005 and V2018 hazard identification and hazard assessment.

 

V2005:

Each food safety hazards shall be evaluated according to the possible severity of adverse health effects,

and the likelihood of their occurrence.

 

V2018:

The organization shall evaluate each food safety hazard with regard to:

a) the likelihood of its occurrence in the end product prior to application of control measures;

b) the severity of its adverse health effects in relation to the intended use

 

Based on the first difference, the 8.5.2.3 hazards assessment is not trying to assess each one of the food safety hazards occurrences in the step, but each one of the food safety hazards occurrences in the end product.

 

So logically, the step only be used for evaluate possibility occurrence, increase, decrease or introduction of the food safety hazards.(see 8.5.1.5.1) And identify the step(s) at which each food safety hazard can be present, be introduced, increase or persist. (see 8.5.2.2.2)

 

And also based on the term "persist", Some hazards may not be decreased or eliminate right in the step where the hazard been identified, but will present in the next step.

[Charles.C]

your document which is be attached, is it still valid to be implemented to determine CCP/OPRP ISO 22000:2018??, so I ask you about reference. I only know decison tree's reference from codex and FSSC interpretation
 

Hi Ahsandro,

 

You may be interested in a CCP/OPRP  decision tree approach for iso22000:2018 (see Pg 159 et seq) which is detailed/exampled in the rather impressive-looking document  available at below link.

 

From a quick look, the Procedure is a (slightly) modified version of the Coca-Cola scheme noted in Post 24 (note my previous additional comments, eg [ii]). .

https://openknowledg...dle/10986/33547

 

Worksheets for the above HACCP/CCP-OPRP categorization approach and additional FS items such as TACCP/VACCP are available here –

https://www.ifc.org/...dbook templates

 

The associated risk matrix is detailed on Pg 169 and appears oriented to a relatively “risk averse” scenario from a generic POV. This is a subjective decision.

[riyas.k.v]

Hai Mr. Charles

 

Excel scoring table shared  in post  22 found useful .

 

I would like to clear the below

 

  41b = ( 41b1 +  41b2 + 41b3 + 41b4)

 

If we score 41b0 it may  give double weightage for the clause  of severity

 

so instead of 9 questions can it reduced to 8 scoring questions . 

 

Riyas

[Charles.C]

Hai Mr. Charles

 

Excel scoring table shared  in post  22 found useful .

 

I would like to clear the below

 

  41b = ( 41b1 +  41b2 + 41b3 + 41b4)

 

If we score 41b0 it may  give double weightage for the clause  of severity

 

so instead of 9 questions can it reduced to 8 scoring questions . 

 

Riyas

 

Hi Riyas,

 

IMO the layout of section 8.5.2.4 is occasionally illogical.

 

Can compare section 8.2.5.4 with the "corresponding" section 7.4.4 in 2005 version.

 

In this selection, each of the control measures as described in 7.3.5.2 shall be reviewed with respect to its effectiveness against the identified food safety hazards.

The selection and categorization shall be carried out using a logical approach that includes assessments with regard to the following:

a)  its effect on identified food safety hazards relative to the strictness applied;
b)  its feasibility for monitoring (e.g. ability to be monitored in a timely manner to enable immediate. corrections);
c)  its place within the system relative to other control measures;
d)  the likelihood of failure in the functioning of a control measure or significant processing variability;
e)  the severity of the consequence(s) in the case of failure in its functioning;
f)   whether the control measure is specifically established and applied to eliminate or significantly reduce the level of hazard(s);
g)  synergistic effects (i.e. interaction that occurs between two or more measures resulting in their combined effect being higher than the sum of their individual effects)

 

.

41b (0-4) are scoring different characteristics.

 

The visually tree-like schemes, eg Coca Cola, have the advantage of  "simplifying" some of these "subtleties".

[aldehit75_murat]

What processes do you use ISO 22000? Purchasing process, production process, storage and transportation process, management review process, quality control process, hygiene and sanitation process.... ? I need a complete list. THANKS FOR HELP. :)

Edited by aldehit75, 03 July 2022 - 03:53 PM.