Bakery HACCP

With respect to the potential presence of E.coli and L. monocytogenes in bakery flour would it be prudent to identify the baking process as an oPRP and to use kill step monitoring as the validation protocol. In actual use then, one would  assign the time / temperature for baking as the monitoring temperature ( would vary for each  product and oven) and would document the process lethality using let's say L.monocytogenes as the reference organism.

The FSMS here is BRC.

Thanks for your time.

With respect to the potential presence of E.coli and L. monocytogenes in bakery flour would it be prudent to identify the baking process as an oPRP and to use kill step monitoring as the validation protocol. In actual use then, one would  assign the time / temperature for baking as the monitoring temperature ( would vary for each  product and oven) and would document the process lethality using let's say L.monocytogenes as the reference organism.

 

The FSMS here is BRC.

 

Thanks for your time.

afaik BRC adhere to Codex HACCP.  afaik the latter makes no reference to the terminology oprp.

Generally, the baking process has been discussed many, many times on this Forum with respect to the possibilities of the step being regarded as -

(1) Having no significant hazard. So no haccp-related control measure required. Many people seem to prefer this.

(2) A CCP  based on capability to "eliminate" all potentially relevant, pathogenic, vegetative, microorganisms. Many (other) people seem to prefer this.

(3 A PRP. There seems to be some limited support for this.

(4) An OPRP. There seems to be some limited support  for this.

All the above can theoretically be justified by some validatory logics as would be required for audit purposes. I have not seen any generally reported auditory exclusions of any of the above when used in appropriate FS Standards..

Perhaps you would like to suggest yr basis for the proposal of an oprp ?.