12 replies to this topic

[asamples]

Hi everyone,

 

forgive me if this is a dumb question but we had our audit back in May and our auditor made some comments (and almost gave NC's) because we have a document called "Prerequisite Programs" and that they're now being referred to as GMPs. He said PRP's is terminology that is no longer being used.

 

is this true? I can't find anything anywhere.

[TimG]

Not unless something has changed I am not aware of. I was trained that GMP's are a specific subset of PRP, but not all PRP's are GMP's.

[The Food Scientist]

GMPs are considered PRPs. They are an example of one PRP. 

 

So I am confused how auditor would say that. 

 

Perhaps he considers all other PRPs under GMPs? Like sanitation, metal detection all GMPs?

Edited by The Food Scientist, 10 August 2020 - 07:40 PM.

[SQFconsultant]

You are operating under a GFSI Scheme such as SQF?

[asamples]

You are operating under a GFSI Scheme such as SQF?

 Correct.

 

I was very confused too. I argued that GMP's are one of our PRP's and he stated that it is no longer being referred to as PRP's. 

[SQFconsultant]

 Correct.

 

I was very confused too. I argued that GMP's are one of our PRP's and he stated that it is no longer being referred to as PRP's. 

 

Yes, your secondary module (let's assume module 11) went from PRP to GMP when it switched up to the new verison.

 

You are lucky you didn't get jigged for, your auditor could have also gigged on SQF practitioner knowledge - always got to stay up to date, this was something I also (as a consultant) missed on the first go around and then I said - whoa, what heck and instituted changes.

[Simon]

Ridiculous if you get an NC for terminology that has zero affect on the operation of your system and safety of your products. For me you can call them Zoingles as long as they are effective.

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[Charles.C]

 Correct.

 

I was very confused too. I argued that GMP's are one of our PRP's and he stated that it is no longer being referred to as PRP's. 

 

As implied in Post 6, it is unfortunately all about context, in this case, that of SQF.

 

SQF have apparently created a bewildering mix of terminologies, eg [from their introductory Guide (!!)] -

 

Module 2 defines the core elements of the SQF Code that provide protection and assurance and are
required to be implemented by all sites seeking SQF certification.  It forms the foundation of the site’s
SQF System.  It includes the commitment of site management to maintain a safe food supply and the
management processes that must be in place to do so; the HACCP plan(s) that identify and control
hazards; the HACCP food safety plan (s) that identifies threats and defines their control; product
traceability and recall; control of foods containing allergens and other foods requiring identity
preservation; and staff training requirements.  
It also points to the industry specific pre-requisite programs that are found in applicable modules 3, 4, 9,
10 and 11 of the SQF Food Safety Code for Manufacturing.  Module 2 must be paired with implementation
of the relevant GAP/GMP/GDP module for SQF Certification to occur.

 

 

The SQF Guidance material illustrates the consequences, eg - from the Code

 

2.4.2.1 The site shall ensure the Good Manufacturing Practices described in modules 3, 4, 9, 10 or 11 (as applicable)
of this Food Safety Code are applied, or exempted according to a written risk analysis outlining the justification for
exemption  or  evidence  of  the  effectiveness  of  alternative  control  measures  to  ensure  that  food  safety  is  not
compromised.

 

 

and from the Guidance -

 

What does it mean?
This series of elements point to the industry sector pre-requisite program (PRP) module (s) (i.e., modules 3
through 15) relevant to the supplier’s scope of certification.  The supplier must implement module 2 AND the
PRP module that applies to the industry sector relevant to their certified product.  Suppliers that are
vertically integrated businesses may need to apply more than one PRP module.  This is explained further in
Part A, 1.2 of the SQF Code, edition 7.
SQFI recognizes that not all food businesses are the same, even though the PRP modules are sector-specific.  
For example, a confectionery business (food sector category 17, module 11) may or may not include cold
storage, depending on the type of confectionery product.  Thus some elements from the PRP modules may
be excluded from audits by explaining via risk assessment documented in the food safety manual the reason
why they are to be excluded.   
In the same way, some businesses may implement an alternative method of control to replace one or some
of the elements in a PRP module.  Where this applies, it must be justified via risk assessment to demonstrate
that control is still in place.  The supplier’s procedures must reflect the alternative control method.

 

 

2.4.2  Auditing Guidance

 

Documentation for the pre-requisite programs (PRPs) will be checked at the desk audit.  This includes -

procedures and work instructions applicable to the relevant PRP module(s), or alternative methods of control. The auditor will confirm compliance to this element at the site audit by interview, observation and sampling and checking records.  Evidence may include:
•  The supplier has documented and implemented the correct PRP module(s);
•  Procedures and or work instructions are in place to cover all applicable PRPs in the relevant PRP module(s);
•  Applicable PRPs are effectively implemented;
•  Exempted PRPs are documented;
•  The effectiveness of PRPs, including alternative controls where applicable, have been verified to ensure that they achieve the desired result
•  Records of PRP validations are available;
•  The property, buildings and equipment meet the PRP requirements, and are clean and achieve hygienic production;
•  Personnel practices and processing techniques meet the PRP requirements and the documented procedures.

 

 

I wonder what the intention was in launching the terminological change ?

[Hoosiersmoker]

So if PRPs are replaced within some modules with only GMPs... is there not a building housing equipment and machinery to produce the items? Buildings, equipment and machinery are all covered under your PRPs but not GMPs. Maybe I'll get involved with that whole "Tell us what you think about Ed 9" discussion because that's just plain confusing, as if it wasn't already sketchy to begin with.

[Hoosiersmoker]

And another thing... If you don't have to address PRPs, which are always supposed to be done BEFORE you address HACCP, but you're required to have a HACCP program, how does that jive?

[Mulan1010]

Agree the Terminology in SQF did change to refer the previously named Pre-Requisite Programs to Good Manufacturing Practices when switched to Version 7.  However, if you fall under USDA Jurisdiction then they still call any programs that support your HACCP Plan Pre-Requisite Programs.  Plus, if you are like our company and have a specific Company Program titled as GMP's then it gets extra confusing.  To compromise, we call the programs listed as Good Manufacturing Practices in SQF as GP's (Good Practices) and maintained the GMP title for our specific program that is titled that way.  For our HACCP Plan we have a sheet titled "HACCP Pre-Requisite Programs" and list each program we use as support in our HACCP Hazard Analysis and that keeps our USDA happy.  I was asked about this by one of the SQF Auditors and she seemed okay with our logic.

[olenazh]

I suspect, SQF is doing that to differentiate somehow from other GFSI schemes. They don't really think of difficulties people're experiencing due to that change...

[Charles.C]

SQF8's Glossary definitions for GMP and PRP are respectively -

 

(1) GMP - The combination of management and manufacturing practices designed to ensure food products are consistently produced to meet relevant legislative and customer specifications.

 

(2) PRP - A procedural measure that when implemented reduces the likelihood of a food safety hazard or a food quality threat occurring, but one that may not be directly related to activities taking place during production.

(Strangely vague definition and with no specific mention of GMP)

 

One can find a substantial range of PRP definitions elsewhere, often longer than those of SQF, eg NACMCF -

 

Prerequisite Programs: Procedures, including Good Manufacturing Practices, that address operational conditions providing the foundation for the HACCP system

 

This thread has some parallels with a previous one which also originated from "confusions" -

 

https://www.ifsqn.co...tc/#entry157452

 

I speculate that the auditor comment referred to in OP reflected some auditor's equally increasing confusion (desperation?).