3 replies to this topic

[Aravind007]

Is Annual validation of pre requisite programs a mandatory requirement in BRC ? Please advise me and any input on validation of pre requisite programs. please provide any examples or templates also if available.

 

thanks       

[Ehab Nassar]

Hi Aravind,

it is not mandatory , below the interpretation of this clause.

Although the prerequisite programme is expected to be eective in achieving the level of control required to ensure food safety, it is not a requirement that a documented validation of every prerequisite is undertaken, as prerequisite programmes typically cover a wide range of general environmental controls, oen with results that are not quantiable. However, where a prerequisite programme is used to manage a specic hazard (e.g. cleaning regimes used to prevent allergen cross-contamination), there needs to be a documented validation that the prerequisite controls the identied hazard (see clause 2.7.3 for further details regarding the validation). Some companies prefer to dierentiate these prerequisites that manage specic hazards from other prerequisites by referring to them as operational prerequisites (oPRPs)

 

Sites that need to meet the requirements of the US Food Safety Modernization Act (FSMA) should note that they must ensure that preventive controls are subject to validation and verication. Some of these controls may cover activities that have traditionally formed part of the prerequisite programme. Later sections of the Standard provide detail on the requirements for eective management of some specic prerequisites, including cleaning (section 4.11), pest management (section 4.14) and training (section 7.1).

Good practice is to review the prerequisite programmes and their management. The frequency of this review should be based on risk, but it could be included, for example, in the annual review of the HACCP or food safety plan.

 

BR,

Ehab 

[Aravind007]

i have a major non conformity for not having the validation for pre requisite program. can i challenge the auditors decision? 

[DannyGFSC]

Depending on the prerequisite program, a validation may be necessary. Where a PRP is specified to control a specific hazard, documented validation must be available. Remember, if you say a PRP is going to do something, you need to prove it is going to do what you say. An exception would be a general PRP that is used to promote and maintain overall food and plant sanitation and therefore cannot be measured but rather serve as a foundation for the control plan. If the PRP is foundational and difficult to measure, you may challenge the auditors findings.