Food Matrix - Chicken & Egg
This is a discussion I have frequently:
The risk matrix (Probability x Impact), regardless of its format, is assessing the risk before PRP's and CCP's are implemented or the remaining risk after these are implemented (which is obviously a Chicken & Egg situation)?
A consultant once told me "the remaining risk after all possible measures are implemented". But that sounds like putting the cart before the horse, as the objective of the matrix is to determine the measures.
Any thoughts?
This is a discussion I have frequently:
The risk matrix (Probability x Impact), regardless of its format, is assessing the risk before PRP's and CCP's are implemented or the remaining risk after these are implemented (which is obviously a Chicken & Egg situation)?
A consultant once told me "the remaining risk after all possible measures are implemented". But that sounds like putting the cart before the horse, as the objective of the matrix is to determine the measures.
Any thoughts?
As I understand yr query is equivalent to "Should PRPs be derived from the risk result of the hazard analysis or designated in advance.
This "before or after topic" has been long argued over in haccp documentation.
afaik most traditional, eg Codex-based, HACCP treatises specify the designation of PRPs prior to initiating hazard analyses. Sort of follows from (satisfactory) GMP (a source of many PRPs) being regarded as a necessary precursor to HACCP.
IIRC, ISO-HACCP, eg iso22000 standard, assumes same chronological order as Codex.
Nonetheless the use of risk assessment to nominate PRPs can certainly be found in some texts also, eg the FSSC 2020 Guidance material for differentiating PRP/CCP/OPRP
As I understand yr query is equivalent to "Should PRPs be derived from the risk result of the hazard analysis or designated in advance.
This "before or after topic" has been long argued over in haccp documentation.
afaik most traditional, eg Codex-based, HACCP treatises specify the designation of PRPs prior to initiating hazard analyses. Sort of follows from (satisfactory) GMP (a source of many PRPs) being regarded as a necessary precursor to HACCP.
IIRC, ISO-HACCP, eg iso22000 standard, assumes same chronological order as Codex.
Nonetheless the use of risk assessment to nominate PRPs can certainly be found in some texts also, eg the FSSC 2020 Guidance material for differentiating PRP/CCP/OPRP
Thank you Charles.
Also applicable legislation may need to be considered, for example:
Thank you Charles.
Also applicable legislation may need to be considered, for example:
FSMAPART 117—CURRENT GOOD MANUFACTURING PRACTICE, HAZARD ANALYSIS, AND RISK-BASED PREVENTIVE CONTROLS FOR HUMAN FOOD117.130 Hazard analysis. Part c) Hazard evaluation. (1)(i) The hazard analysis must include an evaluation of the hazards identified in paragraph (b) of this section to assess the severity of the illness or injury if the hazard were to occur and the probability that the hazard will occur in the absence of preventive controls.Kind regards,Tony
Hi Tony,
TBH, since FSMA appeared, I have studied innumerable articles relating to your quotation but have never succeeded in comprehending the operational meaning/objective/necessity of your underlined phrase (UL). Just for example, does "absence" mean total or a little ? eg consider a cooking step in a process.
IMEX virtually all the related publications quietly skip over the UL since (1) the "impact" of the UL as far as final choice of Preventive Controls are concerned appears to be zero, (2) I suspect the respective authors frequently do not understand the UL's objective either.
Above topic, for me, is horribly reminiscent of the OPRP saga whose generated confusion over 13 years (truly unlucky !) has finally resulted in ISO effectively admitting to a terminological fiasco from which they have now retreated with the 2018 issue of iso22000.
@ anoordende - risk assessment/risk matrices as utilised in haccp only represent the simplified tip of an iceberg. I suggest the topic of pre- and post- probabilities is an analogous situation. Bit like Fisher/Bayesian Estimations.