2 replies to this topic

[lavtak]

Hello, I had a discussion with the food quality team at my company. Since I am still new and reviewing HACCP and my company does not have OPRP. Is it okay if the OPRP is not owned because the company can control it through the PRP? Is OPRP an "obligation" or not? Of course, CCP has already been set

[GMO]

I'm old enough to remember HACCP before oPRPs and HACCP with multiple CCPs which shouldn't have been.  I still maintain that oPRPs are for HACCP teams that can't make a decision...  Ok maybe that's a little over the top.  

 

But sure of course you can have a HACCP plan without an oPRP, just as you can have one without a CCP either.  

 

 

If I'm to get a little on the soapbox though, I'm going to suggest a little bit of controversy here...  I like HACCP.  HACCP appeals to my logical mind.  BUT what it did in the hands of poor practitioners in sites with poor cultures is devalue prerequisite controls.  If you look at any national recall system, what comes up on that system for food recalls are not normally failures of CCPs but failures of prerequisites.  Which I always find fascinating.  You could of course argue the lack of CCP failures mean HACCP is working...  Or you could say it's evidence it's failed!

One for another discussion!

[Tony-C]

Hi lavtak,

 

I  wouldn’t get hung up too much on whether your control of a hazard is by a PRP or an OPRP as long as you have a logical assessment and the hazard is in control. Some relevant info from CODEX and ISO 22000 is posted below.

 

CODEX General Principles of Food Hygiene:

Depending on the nature of the food, food process, and the potential for adverse health effects, to control hazards it may be sufficient to apply GHPs, including, as appropriate, some that require more attention than others, as they have a greater impact on food safety. When the application of GHPs alone is not sufficient, a combination of GHPs and additional control measures at CCPs should be applied.

 

ISO 22000 8.5.2.4 Selection and categorization of control measure(s):

8.5.2.4.1 Based on the hazard assessment, the organization shall select an appropriate control measure or combination of control measures that will be capable of preventing or reducing the identified significant food safety hazards to defined acceptable levels

 

So if you have a significant hazard you need to have appropriate control measures in place with appropriate monitoring, corrective action if necessary and verification.

 

Regarding my point regarding the important thing is for you to control your hazard (rather than worry whether you should call it a PRP or an OPRP) and GMO’s comment regarding failures of prerequisites, below are some statistics I quote in the IFSQN Practical HACCP Training:

 

FDA Recalls, Market Withdrawals & Safety Alerts - Analysis of FDA Recall Notices from 2017 onwards shows:

51% of the alerts were due to incorrect labelling/undeclared allergens.

34% were due to contamination with well known environmental pathogens Salmonella and Listeria.

 

I would think the majority of which would have been due to failure of prerequisites rather than CCPs.

 

Kind regards,

 

Tony