I'm so old OPRPs weren't a thing when I started doing HACCP plans :)
However, I'm working on a HACCP plan for bottling alcoholic beverages (spirits - whisky, rum, vodka).
Using our Corporate Tech Services decision tree is leading me to a quandary. I've always considered the risk of glass contamination as a CCP
but our process to control this hazard is to monitor the air and water cleaning lines (depending on which line the product is running on) to ensure the pressure is within specification
and to visually inspect that the air/water cleaning equipment is working appropriately. (Empty Bottles are manually dumped from cases and then inverted and either air or water washed before being filled)
the question in our Decision Tree says " Is the frequency of monitoring/checking the control measure sufficient to enable immediate corrective action? If yes, CCP, if no OPRP.
As we do not have any sort of immediate way to tell (eg no alarms to alert if the pressure should drop below spec) , we have containment and rework procedures to deal with an eventuality of finding that the control has broken down between the hourly checks.
So, in that case, is it an OPRP - despite the fact that glass contamination is critical?
Sorry if this sounds a ridiculous question.
Eventually we will want to certify this to FSC22000 standard, but we've a ways to go yet.
Is the frequency of monitoring/checking the control measure sufficient to enable immediate corrective action If Yes, - CCP, If No - OPRP