Jump to content

  • Quick Navigation
Photo
- - - - -

FSSC 22000 V 5.1 Clause 2.5.12 PRP Verification Interpretation

PRP 2.5.12 PRP Verification

  • You cannot start a new topic
  • Please log in to reply
15 replies to this topic

#1 Shere- Dean

Shere- Dean

    Grade - Active

  • IFSQN Active
  • 24 posts
  • 10 thanks
3
Neutral

  • Jamaica
    Jamaica

Posted 22 March 2021 - 10:04 PM

Good day, can someone provide clarification on the new FSSC 22000 V 5.1 clause, 2.5.12 PRP Verification (for food chain category C). Does anyone have a risk assessment they are willing to share or provide a link etc that can help with interpreting this clause?

How are you meeting the new requirement at your organization? Thanks in advance!



#2 jdpaul

jdpaul

    Grade - MIFSQN

  • IFSQN Member
  • 222 posts
  • 179 thanks
38
Excellent

  • United States
    United States

Posted 24 March 2021 - 01:44 PM

Do you have the PRP technical standard scheme 22001-2? The easiest thing to do would be to make an audit checklist 

 

for instance, 

 

in the ISO 22001-2 PRP technical standard, you have the following PRPs

 

4 Construction and layout of buildings..................................................................................................4
5 Layout of premises and workspace ....................................................................................................5
6 Utilities – air, water, energy..................................................................................................................6
7 Waste disposal ......................................................................................................................................8
8 Equipment suitability, cleaning and maintenance.............................................................................9
9 Management of purchased materials ................................................................................................10
10 Measures for prevention of cross contamination............................................................................11
11 Cleaning and sanitizing ......................................................................................................................12
12 Pest control..........................................................................................................................................13
13 Personnel hygiene and employee facilities......................................................................................14
14 Rework..................................................................................................................................................16
15 Product recall procedures..................................................................................................................17
16 Warehousing........................................................................................................................................17
17 Product information/consumer awareness ......................................................................................18
18 Food defence, biovigilance and bioterrorism...................................................................................18
 
 
 
you would need to do this for all 18, but using as an example PRP 18 Food Defense, biovigilance and bioterrorism, I would have a checklist (made against the PRP 18 requirements) like below
 
  1. Have all sensitive areas been identified and secured or otherwise access controlled using locks, badge access, or other measures to restrict access to authorized personnel only? 
  2. Have acts of sabotage, vandalism, and terrorism that could affect sensitive processes or products been assessed and mitigated by protective controls?

you would answer those questions as such (compliant, not compliant (e.g., new sensitive area identified and not access restricted, etc.) And at the end of the entire verification audit you will probably want a summary of the results (e.g. what was found, what PRPs needs to be improved, etc.)

 

 

I am guessing you are doing something like this anyway since ISO 22000 basically requires the food safety team to review and verify PRPs (see section 8.2 in ISO 22000:2018)


Edited by jdpaul, 24 March 2021 - 01:52 PM.


Thanked by 1 Member:

#3 ToniAllardyce

ToniAllardyce

    Grade - Active

  • IFSQN Active
  • 6 posts
  • 0 thanks
0
Neutral

  • Canada
    Canada

Posted 31 March 2021 - 05:21 PM

As the previous poster stated is create a checklist or do an annual reassessment to the individual point to the standard. In Canada theolder plants have the FSEP PRP's that had to have at minimum an annual reassessment done to ensure they were being implemented as it was written



#4 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,238 posts
  • 5113 thanks
1,113
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 31 March 2021 - 07:43 PM

 

2.5.12 PRP VERIFICATION (FOOD CHAIN CATEGORIES C, D, G, I & K)

 For food chain categories C, D, G, I and K, the following additional requirement applies to ISO22000: 2018 clause 8.8.1:  
• The organization shall establish, implement and maintain routine (e.g. monthly)
site inspections/PRP checks to verify that the site (internal and external),
production environment and processing equipment are maintained in a suitable
condition to ensure food safety. The frequency and content of the site
inspections/PRP checks shall be based on risk with defined sampling criteria and
linked to the relevant technical specification.

 

A summary of above is  -

SECTION 2.5.12: Prerequisite Programmes Verification

A programme to verify PRPs must be established and maintained and shall be based on the risk assessment. The risk assessment must follow the defined criteria and technical specification and ensure product safety.

This requirement is applicable to the following food categories; C, D, E, F, I and K.

(https://ascconsultan...00-v5-1-changes)
ADDED - ABOVE INTERPRETATION MAY BE INACCURATE - SEE POST 5 ET SEQ

Seems that fssc's  additional "risk" clause is interpreted as applying to verification activities for  ALL the PRPs involved in following clause of iso22000 FSMS standard (WOW !!, Shades of a BRC-type philosophy) -

 

8.8.1The  organization  shall  establish,  implement  and  maintain  verification  activities.  The  verification planning shall define purpose, methods, frequencies and responsibilities for the verification activities.
The verification activities shall confirm that:
a)  the PRP(s) are implemented and effective;

 

However, as contemplated in previous Posts, there is no mandated  minimum frequency, eg an interval in range of 1month - 1year is theoretically acceptable if "based on risk".

 

JFI, Generally -

Verifying PRPs and CCPs
Many processors may understand that verification of CCPs and PRPs is essential to food safety, but there are others who simply do not fully comprehend how this should be done. There are four major types of verification activities:

• A non-audit review of documents. An example is reviewing CCP records to ensure that a specific lot of product complies with the HACCP plan.

• Conducting various measurements and assessment activities to ensure a PRP or the product is operating within defined parameters. An example is to collect environmental microbial swabs to ensure that the cleaning and sanitizing program is compliant with internal specifications, and to measure the microbial parameters of products.

• Conducting various assessments to determine if other components of the FSMS are operating within defined parameters. Examples include determining if training is effective, conducting mock recalls or ensuring that measurement equipment is properly calibrated.

Internal and external audits. The function of audits is to provide an unbiased assessment of the FSMS.4510ProcessControlTable3(1).jpg
The first step is in developing a verification program is to determine all of the processes that need to be verified (see Table 2). Next, a verification plan needs to be developed for each part of the FSMS. Table 3 provides an example of part of a verification plan.

(https://www.food-saf...orking#Sidebar1)
(The iso interpretation of verification is also detailed/exampled at considerable length in iso22004)

Attached File  Table2.PNG   231.74KB   2 downloads

 

Just as an illustration, some "Verification Activities" in Table 3 above  are exampled below for a Dairy Process/iso22002-1 -

Attached File  Verification Activities, iso22002-1.pdf   157.4KB   55 downloads

 

It seemed to me that, if "risk" is applied to all 18 sections (and subs?) in Post 2, the effort involved may not be negligible.

Maybe simpler to generate a Verification H/M/L Global Risk Assessment (eg ranging 3/6/12 months) over the various Sections of iso22000 including Section 8. Or perhaps a retrospective risk analysis approach  as previously exampled on this forum. This utilises a semi-generic template which could be repeated or cross-linked to a batch of relevant frequencies, etc, eg see the (BRC) examples/cross-references in this short thread -

 

https://www.ifsqn.co...nts/#entry58503


Edited by Charles.C, 05 April 2021 - 06:27 PM.
edited/corrected (see BLUE above)

Kind Regards,

 

Charles.C


Thanked by 1 Member:

#5 Koko LMQ

Koko LMQ

    Grade - MIFSQN

  • IFSQN Member
  • 122 posts
  • 26 thanks
4
Neutral

  • Thailand
    Thailand

Posted 04 April 2021 - 12:22 AM

Just a simple "site / infrastructure inspection checklist" with criteria for checking, e.g. building, floor etc. and ensure the criteria met the ISO/TS 22002-X. It is required by GFSI Benchmarking Requirement, not all PRPs in ISO/TS 22002-x.



#6 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,238 posts
  • 5113 thanks
1,113
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 04 April 2021 - 06:18 PM

Just a simple "site / infrastructure inspection checklist" with criteria for checking, e.g. building, floor etc. and ensure the criteria met the ISO/TS 22002-X. It is required by GFSI Benchmarking Requirement, not all PRPs in ISO/TS 22002-x.

 

Hi Koko,

 

Thanks input. 

 

Re ^^^(red). I hope you are correct. However the clause 2.5.12 specifically states "additional requirement applies to ISO22000: 2018 clause 8.8.1" and I observed that my 2nd quote above in Post 4 seemed to have  interpreted "risk' as being required for all  PRPs.

 

IMO the "applies to" text in clause 2.5.12 is ambiguous. The original text in GFSI (somewhere?) which presumably forced this addendum may clarify the intention.

 

PS - IMHO, it would have been advantageous for users if fssc had revised clause 8.8.1 rather than to just keep throwing in all these addenda but they don't own iso22000 of course. :smile:


Kind Regards,

 

Charles.C


#7 Koko LMQ

Koko LMQ

    Grade - MIFSQN

  • IFSQN Member
  • 122 posts
  • 26 thanks
4
Neutral

  • Thailand
    Thailand

Posted 05 April 2021 - 08:21 AM

Hi Charles C.

Here it is GFSI requirement. Risk can be assessed by product type or production zone, e.g. high risk/high care area should be checked more frequent.

Best regards,
KOKO_LMQ


Edited by Koko LMQ, 05 April 2021 - 08:22 AM.


#8 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,238 posts
  • 5113 thanks
1,113
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 05 April 2021 - 08:44 AM

Hi Charles C.

Here it is GFSI requirement. Risk can be assessed by product type or production zone, e.g. high risk/high care area should be checked more frequent.

Best regards,
KOKO_LMQ

 

Hi Koko,

 

Thks but I'm not too sure of the relevance of yr comment ?.

 

Can you post the relevant (to PRP Verification issue) GFSI text or provide a link ?


Kind Regards,

 

Charles.C


#9 Koko LMQ

Koko LMQ

    Grade - MIFSQN

  • IFSQN Member
  • 122 posts
  • 26 thanks
4
Neutral

  • Thailand
    Thailand

Posted 05 April 2021 - 01:28 PM

Hi Charlies,

 

Here it is "GMP 10 - Site inspections / checks : A programme of site inspections / checks shall be established, implemented and maintained to ensure the site environment and processing equipment are maintained in a suitable condition to ensure food safety, as applicable to the activity of the site."

KOKO_LMQ

Attached Files


Edited by Koko LMQ, 05 April 2021 - 01:33 PM.


#10 Koko LMQ

Koko LMQ

    Grade - MIFSQN

  • IFSQN Member
  • 122 posts
  • 26 thanks
4
Neutral

  • Thailand
    Thailand

Posted 05 April 2021 - 01:32 PM

Hi Charles,

You can see the self-assessment checklist from FSSC/GFSI - GMP 10.

KOKO

Attached Files



#11 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,238 posts
  • 5113 thanks
1,113
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 05 April 2021 - 03:48 PM

Hi Koko,

 

Thks yr attachment, etc. I deduce the pdf is sourced from FSSC, not GFSI.

 

I am still assimilating the info provided however my initial reaction is that FSSC's Verification "risk-related " content  is not a GFSI  requirement per se  (ie not a specific GFSI benchmark requirement). It appears to be "inspired" by FSSC themselves.

 

I was also rather intrigued by the GFSI comment - <<< Included in draft V5.1 as additional requirement to internal audits >>>

(I deduce that the item listed as "GMP 10" was introduced in GFSI's benchmarking requirements ver. 2020 and did not exist in FSSC22000 version 5)

 

PS - afaik, this is a "typical" GFSI 2020 benchmark compilation (as per yr Post 9) -

 

Attached File  9-Benchmarking_Requirements_v2020_Part3_c1.pdf   229.93KB   33 downloads


Edited by Charles.C, 05 April 2021 - 06:43 PM.
added

Kind Regards,

 

Charles.C


#12 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,238 posts
  • 5113 thanks
1,113
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 05 April 2021 - 06:46 PM

Hi Koko,

 

I think I agree with the basic interpretations in yr Posts 5, 7 (Except for the owner of the risk-related text :smile: ) .

Thks again.


Kind Regards,

 

Charles.C


#13 Koko LMQ

Koko LMQ

    Grade - MIFSQN

  • IFSQN Member
  • 122 posts
  • 26 thanks
4
Neutral

  • Thailand
    Thailand

Posted 06 April 2021 - 01:38 AM

Hi Koko,

 

I think I agree with the basic interpretations in yr Posts 5, 7 (Except for the owner of the risk-related text :smile: ) .

Thks again.

 

Dear Charles,

 

All attachments sourced from GFSI public comment made to FSSC benchmarking with GFSI requirements. Correct, additional "risk based", came from FSSC 2000. But the point I comment is the site inspection or fabrication inspection, not all PRPs as in ISO/TS 22002-1.Risk based should be made like, more frequent in High Risk or High Care area or open product areas (like BRCGS Food Issue 8).

KOKO



#14 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,238 posts
  • 5113 thanks
1,113
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 06 April 2021 - 02:22 AM

Hi Koko,

 

TBH I don't really understand why GMP 10 was added by GFSI since it seems to me that it's content is already adequately covered within the existing GMPs listed by GFSI (ie within iso22002-1).

Similarly I consider that FSSC's further addition of a, one-off, risk based, checking frequency was equally redundant. It might have made fractionally more sense IMO if it was required for all the PRPs.

 

Even BRC who are surely the GFSI's King of Risk-based Requirers don't require the above for any PRPs. (although BRC instead  do require Validation unlike afaik everybody else)(SQF used to want it but finally gave up after avalanching auditorial confusions).

 

Maybe GFSI/FSSC are simply running out of things to revise.


Kind Regards,

 

Charles.C


#15 Z Chemist

Z Chemist

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 1 thanks
0
Neutral

  • Jamaica
    Jamaica

Posted 08 April 2021 - 08:35 PM

Hi, 

 

Currently I do a verification every 3 month but I noticed the standard stated "for example monthly"? Is it that the auditor may be looking for a monthly verification?



#16 Charles.C

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,238 posts
  • 5113 thanks
1,113
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 09 April 2021 - 01:15 AM

Hi, 

 

Currently I do a verification every 3 month but I noticed the standard stated "for example monthly"? Is it that the auditor may be looking for a monthly verification?

See Post 13, last sentence.


Kind Regards,

 

Charles.C






1 user(s) are reading this topic

0 members, 1 guests, 0 anonymous users