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Codex Decision tree in ISO 22000:2018 - Clause 8.5.2.4

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Nicole Haddad

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Posted 28 April 2020 - 08:40 PM

Hello,

 

While working on clause 8.5.2.4, I came across the following right after the hazard assessment part:

 

"Based on the hazard assessment, the organization shall select an appropriate control measure or combination of control measures that will be capable of preventing or reducing the identified significant food safety hazards to defined acceptable levels.
The organization shall categorize the selected identified control measure(s) to be managed as OPRP(s) (see 3.30) or at CCPs (see 3.11)."
 
The thing is that I don't see the purpose of using the traditional codex decision tree because:
1- the significant hazards will be considered as CCP or OPRP - no chance for PRP 
2- deciding whether the control measure will be a CCP or OPRP is defined in the standard as follows -  I intend to have a decision tree based on 8.5.2.4.2 :
 
"The categorization shall be carried out using a systematic approach. For each of the control measures selected, there shall be an assessment of the following:
a) the likelihood of failure of its functioning;
b) the severity of the consequence in the case of failure of its functioning; this assessment shall include:
1) the effect on identified significant food safety hazards;
2) the location in relation to other control measure(s);
3) whether it is specifically established and applied to reduce the hazards to an acceptable level;
4) whether it is a single measure or is part of combination of control measure(s).
 
8.5.2.4.2 In addition, for each control measure, the systematic approach shall include an assessment of the feasibility of:
a) establishing measurable critical limits and/or measurable/observable action criteria;
b) monitoring to detect any failure to remain within critical limit and/or measurable/observable action criteria;
c) applying timely corrections in case of failure."
 
Please share your thoughts and experience; many thanks in advance!

 

 



Charles.C

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Posted 29 April 2020 - 02:01 AM

 

Hello,

 

While working on clause 8.5.2.4, I came across the following right after the hazard assessment part:

 

"Based on the hazard assessment, the organization shall select an appropriate control measure or combination of control measures that will be capable of preventing or reducing the identified significant food safety hazards to defined acceptable levels.
The organization shall categorize the selected identified control measure(s) to be managed as OPRP(s) (see 3.30) or at CCPs (see 3.11)."
 
The thing is that I don't see the purpose of using the traditional codex decision tree because:
1- the significant hazards will be considered as CCP or OPRP - no chance for PRP 
2- deciding whether the control measure will be a CCP or OPRP is defined in the standard as follows -  I intend to have a decision tree based on 8.5.2.4.2 :
 
"The categorization shall be carried out using a systematic approach. For each of the control measures selected, there shall be an assessment of the following:
a) the likelihood of failure of its functioning;
b) the severity of the consequence in the case of failure of its functioning; this assessment shall include:
1) the effect on identified significant food safety hazards;
2) the location in relation to other control measure(s);
3) whether it is specifically established and applied to reduce the hazards to an acceptable level;
4) whether it is a single measure or is part of combination of control measure(s).
 
8.5.2.4.2 In addition, for each control measure, the systematic approach shall include an assessment of the feasibility of:
a) establishing measurable critical limits and/or measurable/observable action criteria;
b) monitoring to detect any failure to remain within critical limit and/or measurable/observable action criteria;
c) applying timely corrections in case of failure."
 
Please share your thoughts and experience; many thanks in advance!

 

 

Hi Nicole,

 

Please see this post and the surrounding thread -

 

https://www.ifsqn.co...18/#entry138153


Kind Regards,

 

Charles.C


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Posted 29 April 2020 - 02:58 AM

Hi Ncole,

 

You are absolutely correct.as per the standard, its ask for - categorization carried out using a systematic approach. as you said Codex Decision tree is only one approach of categorizing of control measures :spoton:.

 

Thanks

EC



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Charles.C

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Posted 29 April 2020 - 03:22 AM

Hi Ncole,

 

You are absolutely correct.as per the standard, its ask for - categorization carried out using a systematic approach. as you said Codex Decision tree is only one approach of categorizing of control measures :spoton:.

 

Thanks

EC

 

Actually one of the originators of iso22000 stated -

 

 ISO 22000 introduces the notion of operational PRP to cover  the  « significant »  hazards  which  are  not attributed to a HACCP plan (that is to a CCP) ;From  then  on,  the  Codex  decision  tree  is  no  longer adopted  and  must  be  replaced  by  a  reproducible method which allows the attribution of the surveillance of control measures either to the HACCP plan or to an operational PRP.

 

 

@Nicole - As you imply, relative to the hazard analysis, the PRPs are pre-defined. Therefore, if function verified, any related hazard should be non- significant.


Edited by Charles.C, 29 April 2020 - 03:36 AM.
added

Kind Regards,

 

Charles.C


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Nicole Haddad

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Posted 30 April 2020 - 11:29 PM

I am doing my best to stick to the codex decision tree - which I dislike - because I am concerned that the auditor would not accept a "customized" approach.

I guess I will wait for my next project to adopt my drafted approach.

 

The approach that I drafted is similar to what Charles had shared, it includes all the requirements in the standard.

 

Rationale: significant hazards will have to be either CCPs or OPRPs 

 

Step 1: The following questions are used to obtain OPRPs and proceed with potential CCPs to step 2:

a) establishing measurable critical limits and/or measurable/observable action criteria;
b) monitoring to detect any failure to remain within critical limit and/or measurable/observable action criteria;
c) applying timely corrections in case of failure."

 

Potential CCPs will go through Step 2:

A weight is attributed for the following questions to obtain a cumulative score rather than having them in a decision tree that concludes a CCP after 1 or few questions:

a) the likelihood of failure of its functioning;

b) the severity of the consequence in the case of failure of its functioning; this assessment shall include:
1) the effect on identified significant food safety hazards;
2) the location in relation to other control measure(s);
3) whether it is specifically established and applied to reduce the hazards to an acceptable level;
4) whether it is a single measure or is part of combination of control measure(s).

PS: I combined 2) & 4) into:Is this the last measure to reduce this hazard to an acceptable level within the process?





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