7 replies to this topic

[woo333]

Last year in our FSSC audit, we have archived the old HACCP plan and used the FSMA Food Safety Plan template as our Hazard Analysis. The auditor challenged us why the OPRP are removed in the new plan (ie. Magnet and destoning was OPRP in the old plan and now they are covered under the PRP foreign material control)  

No NC was issued last year, but the auditor was hinting that I should review it in depth for next year. 

 

I am planning to redo my hazard analysis this year, does anyone have a good HACCP/FSP template of the HA that covers both FSSC & FSMA requirements?

 

Appreciate your help on this.

[Ooi]

Hello there.

 

See from fssc22000.com: FSSC 22000 revised their FSMA Addendum - FSSC (some links therein "Not found" though).

 

They used to have a template, but I can't find it anywhere now.

Well if you don't mind an older version (v4.1), see attached.

Attached Files

•  fssc-22000-fsma-alignment-v1-final-september-2017-7.xlsx   135.76KB   99 downloads

[Charles.C]

Last year in our FSSC audit, we have archived the old HACCP plan and used the FSMA Food Safety Plan template as our Hazard Analysis. The auditor challenged us why the OPRP are removed in the new plan (ie. Magnet and destoning was OPRP in the old plan and now they are covered under the PRP foreign material control)  

No NC was issued last year, but the auditor was hinting that I should review it in depth for next year. 

 

I am planning to redo my hazard analysis this year, does anyone have a good HACCP/FSP template of the HA that covers both FSSC & FSMA requirements?

 

Appreciate your help on this.

Hi woo,

 

I don't quite understand how you can replace a FSSC-oriented haccp plan by one which is FSMA "compliant".

 

Just by visual observation, some (Codex/ISO) haccp definitions/terminologies/interpretations are surely not aligned ??

 

Does FSMA/HARPC, per se, anywhere even define (their own?) OPRP ?

[Sayed M Naim Khalid]

I would consider the food safety plan as an umbrella. Thus, I would develop a full HACCP plan and make it part of the Food Safety Plan. However, if you implement a specific standard like ISO 22000/FSSC22000 or others, you will need to have to Books for that standard and then a separate one for Food Safety Plan. Simply speaking, they can compliment each other. 

 

OPRP - it is more a terminology used in ISO 22000 than other standards or government regulations. If you specifically looking for oPRP, I would recommend going through the ISO 22000 because its a terms from ISO. 

 

You can check info about OPRP on the UK Food Standards Agency with some examples - Operational Prerequisite Programmes (OPRPs) | MyHACCP (food.gov.uk)

[Scampi]

woo333, you've forgotten that you also need to comply with SFCR

 

ditching a traditional HACCP plan seems like a mistake to me, particularly where CFIA and FSSC are concerned as they both require a robust HA--I suggest you pull it out of archive and use that as your launch pad

 

There are so many names for THE SAME THING floating around that sometimes the best thing is to take a breath an THINK about your proposed changes and the full implications before dropping things like the proverbial hot potato

 

 

I have added clause numbers to the headers of my program-------satisfies everyone involved WITHOUT having to create an entirely separate plan

 

At the heart of every audit scheme is a HACCP plan, and just because FSMA has decided to change the names, doesn't mean they aren't (or a lot of them anyway) identical

 

Any well analyzed and written HACCP plan should have already had PRP, it's a part of the 12 steps--------and has ALWAYS been a Food Safety Plan or System.  To quote shakespeare, "A rose by any other name would smell as sweet"

 

Use the KISS method where and when ever possible

[G M]

...

There are so many names for THE SAME THING floating around that sometimes the best thing is to take a breath an THINK about your proposed changes and the full implications before dropping things like the proverbial hot potato

 

I have added clause numbers to the headers of my program-------satisfies everyone involved WITHOUT having to create an entirely separate plan

 

At the heart of every audit scheme is a HACCP plan, and just because FSMA has decided to change the names, doesn't mean they aren't (or a lot of them anyway) identical

...

 

 

I've done something similar with most of our policies and core safety and quality programs, they have a little section near the beginning that lists the various regulations and standards it is meant to keep us in compliance with.  Most of our documents fall under three groups and are numbered accordingly: Prerequisite, Safety, Quality.  I do what I can to push any new material or customer specifications into an existing document to keep redundancy to a minimum.

[Charles.C]

I would consider the food safety plan as an umbrella. Thus, I would develop a full HACCP plan and make it part of the Food Safety Plan. However, if you implement a specific standard like ISO 22000/FSSC22000 or others, you will need to have to Books for that standard and then a separate one for Food Safety Plan. Simply speaking, they can compliment each other. 

 

OPRP - it is more a terminology used in ISO 22000 than other standards or government regulations. If you specifically looking for oPRP, I would recommend going through the ISO 22000 because its a terms from ISO. 

 

You can check info about OPRP on the UK Food Standards Agency with some examples - Operational Prerequisite Programmes (OPRPs) | MyHACCP (food.gov.uk)

Hi SMNK,

 

It appears that  FSA desire that their "OPRP" should be regarded as equivalent to that "patented" by ISO22000. The FSA linked article is undated but I deduce to originate from the period 2016-2017. No updates are mentioned.

 

Unfortunately The 2nd version of iso22000 in 2018 has rendered some of the content in FSA's article and its EC reference both obsolete.. Notably ISO's explicit  "linkage" of  "OPRP" to Prerequisite Programs (despite the name) has been removed.

 

My personal opinion regarding "OPRP" is that it has achieved nearly 20 years of (unended) discussion  but whose conclusion  remains as murky as when it started. I suspect it will eventually (2050?) suffer the same fate as "CCP2".

 

I remain interested in FSMA's expressed opinion of the usage of OPRP (if any).

Edited by Charles.C, 15 February 2023 - 04:42 PM.
edited

[woo333]

Hi Everyone, really appreciated you sharing your insights on this. I am glad I was not crazy to reintroduced an archived document.

Long story short, we hired a consultant and he proposed to replace the FSSC-HACCP completely.

I was doing my reassessment since January and I felt the analysis is more complete with the old HA compared to the Food safety plan created by the consultant. 

Your answers helped me confirmed I am in the right mind that I should bring back the HACCP plan as part of my system.

Thank you!