10 replies to this topic

[suhaibalbadawi97]

Hello everyone,

when making a hazard control plan in iso 22000 , if the control measure is categorization to PRP accept or not

or the control mesure shell categorization to ccp and oprp only

any Explanation from standard
👋👋

[Charles.C]

Hello everyone,

when making a hazard control plan in iso 22000 , if the control measure is categorization to PRP accept or not

or the control mesure shell categorization to ccp and oprp only

any Explanation from standard

Hi Suhaib,

 

Sorry but your specific question is unclear to me. Can you clarify ?

[suhaibalbadawi97]

Hi Suhaib,


ok
I want a reference that says prp is a control measure

Sorry but your specific question is unclear to me. Can you clarify ?

[suhaibalbadawi97]

ok
I want a reference that says prp is a control measure

[Charles.C]

ok
I want a reference that says prp is a control measure

I have seen this debated both ways.

 

If you would like one affirmative reference -

 

 

PRP: Prerequisite Programs

Food safety practices and programs are in place to address the production environment’s role in safe food production. They’re a set of general control measures that may or may not be measurable. Therefore, monitoring and documenting them are often not at the same level as CCPs. They aren’t specific to one step in the process and do not control a specific hazard as CCPs do. They ensure that the environment is maintained hygienically to reduce food safety risks. You’ll need to document the management process for these programs,

https://www.etq.com/...p-oprp-podcast/

 

The above quote is also debatable.

[Charles.C]

and here is a (iso22000:2018) contrary opinion -

 

 PRP not a control measure in iso 220000.png   160.44KB   1 downloads

 

https://www.exaris.f...p-prpo-en.phtml

Edited by Charles.C, 14 September 2023 - 05:33 AM.
added

[Tony-C]

Hi suhaibalbadawi97 and Charles,

 

An interesting question and I find that ISO 22000 adds to the confusion here with the definitions given:

 

ISO 22000:2018 Food safety management systems — Requirements for any organization in the food chain

 

3.8 Control Measure

Action or activity that is essential to prevent a significant food safety hazard (3.22) or reduce it to an acceptable level (3.1)

 

3.35 Prerequisite Programme PRP

Basic conditions and activities that are necessary within the organization (3.31) and throughout the food chain (3.20) to maintain food safety

Note 1 to entry: The PRPs needed depend on the segment of the food chain in which the organization operates and the type of organization. Examples of equivalent terms are: good agricultural practice (GAP), good veterinary practice (GVP), good manufacturing practice (GMP), good hygiene practice (GHP), good production practice (GPP), good distribution practice (GDP) and good trading practice (GTP).

 

Some PRPs will be control measures for example ISO 22002-1 9.3 Incoming material requirements (raw/ingredients/packaging)

Delivery vehicles shall be checked prior to, and during, unloading to verify that the quality and safety of the material has been maintained during transit (e.g. integrity of seals, freedom from infestation, existence of temperature records).

Materials shall be inspected, tested or covered by COA to verify conformity with specified requirements prior to acceptance or use. The method of verification shall be documented.

 

Other PRPs will be standards for hygienic operation for example, having a hygienic design or a smooth surface is neither an action or activity.

 

Seems like the contradiction is that PRPs are not normally “essential to prevent a significant food safety hazard” and so according to ISO 22000 cannot be a control measure? 

 

Kind regards,

 

Tony

 

[suhaibalbadawi97]

ok ..
conclude from this that when making a HACCP plan, it is not allowed to set any point in flow chart as PRP

thank you all

[Charles.C]

ok ..
conclude from this that when making a HACCP plan, it is not allowed to set any point in flow chart as PRP

thank you all

It depends on what the activity is. For example, the stage of  "receiving raw materials" typically involves  PRPS.  (see Tony's Post).

I suggest you study some  iso-based  HACCP Plans.

 

I agree with Tony that ISO have created a bit of a mess/contradiction with their interpretations. One benefit is that I anticipate most auditors are equally confused so tend to be "flexible".

 

JFI might note that Codex has a similar definition of "control measure" to iso22000 (minus the "Notes") but seemingly interprets it's definition in a different, ie more flexible, way. Their approach is illustrated by this extract from Codex Hygiene,2022

 

 Control Measure - Codex.pdf   266.67KB   30 downloads

 

PS - I also noticed that the terminology "control measure" is occasionally used within the ISO22002-X Series of Prerequisite Programs.

Edited by Charles.C, 17 September 2023 - 07:15 AM.
added

[Charles.C]

Once again, JFI, FDA/Juice HACCP  seemingly invokes another manouevre to respond to the "Is PRP a "control measure" ?" via the terminology "HACCP Control Measure" , eg -

 

 

V. Control Measures A. HACCP Control Measures

Under 21 CFR 120.8(a), you are required to implement HACCP control measures if you determine in your hazard analysis that a food hazard is reasonably likely to occur in your juice product.

Examples of HACCP control measures used in the processing of juice include measures carried out at CCPs specified in a HACCP plan such as the pasteurization of juice for the elimination of microbial pathogens; the culling or trimming of apples after storage to eliminate moldy, damaged, bruised, or rotten apples to ensure that patulin will not be present at levels of concern in the finished apple juice; and periodically monitoring processing lines for evidence of glass breakage.

B. Activities Not Considered to be HACCP Control Measures

Some activities firms may undertake in processing juice and in related functions are not HACCP control measures. These include Good Agricultural Practices (GAPs) and Current Good Manufacturing Practices.

https://www.fda.gov/...idance-first#iv

 

(Note that there are no textual mentions of "PRP" in the above webpage).

 

IMO much of this topic is ultimately more related to Semantics than HACCP. Presumably one could simply use "Preventive Measures" in any hazard analysis tables rather than "Control Measures".

[Charles.C]

Once again, JFI, FDA/Juice HACCP  seemingly invokes another manouevre to respond to the "Is PRP a "control measure" ?" via the terminology "HACCP Control Measure" , eg -

 

 

 

(Note that there are no textual mentions of "PRP" in the above webpage).

 

IMO much of this topic is ultimately more related to Semantics than HACCP. Presumably one could simply use "Preventive Measures" in any hazard analysis tables rather than "Control Measures" as was, I think, usual in older haccp plans..