But our company has been certified ISO 22000-2005 and now we are transitioning to 2018 version, we have to follow the standard.
in your previous attachment itself it is explained that sieving step can be monitored by measuring the mesh size. Continuous monitoring is possible here and frequency can be fixed based on the historical data.
Note that i said I did not agree with all the content of my attachment.
IMO the opening paragraph of sec.3 is simply a semantic fudge.
Similarly the last paragraph of sec.1.
I also found it curious that the attachment seemingly ignored iso22002-1 with respect to sec.10.
Whatever, the Standard's experts introduced these artificial subtleties and deserve to face the consequences.
All these semantic zigzags plus aspects like the attempts to justify the continuing use of OPRP are IMO why this Standard is an absolute mess from a haccp POV.
There are 2 more prolonged/contentious threads on this topic here -
Regardless of the endless debate over hazardous, particle sizes, I am impressed that you can continuously monitor the mesh size. How do you do it ?
Once again, IMO, the direct cause for all these headaches lies with the Standard, not the users. Perhaps the real objective was to increase the use of OPRPs.
PS just as one sieving PRP illustration for a non-iso plan -
haccp plan-black pepper.png 740.21KB
and one sieving PRP/CCP -
kraft - extraneous material.png 256.4KB
and even a metal detector PRP/CCP -
There is an ongoing debate as to how a company’s metal detector should be incorporated into the organization’s food quality and safety programs. Some companies have determined that metal detection should be a CCP in their Hazard Analysis and Critical Control Points (HACCP) plan, whereas others deem it part of quality management (prerequisite program).
If the manufactured products are chopped or ground, and the company’s Hazard Analysis determines that there is a significant potential for metal contamination, the company will probably adopt the former. However, if a processor is producing purées or juices, it might install an in-line metal detection unit not only to look for metal but also to protect equipment that is located downstream of the unit. Of course, there are processors that base this decision not on risk but on customer demands. If a processor’s primary customer demands that metal detection be a CCP, they will usually comply.
PPS - Most auditors are surely well aware of all these interpretations which must give them equal headaches. Unless individual experience dictates otherwise, I suspect that in practice any of the 3 options may be acceptable provided that the associated Va/Ve data is "plausible" .