Do oPRPs Still Provide Value Under FSMA and FSSC?
I'm going to fess up from the start, I've never been a huge fan of oPRPs but I've assigned one in a factory before. I do think they bring in vagueness where it's not all that helpful.
But since FSMA, I think for sites supplying the US, oPRPs bring in a level of complexity which doesn't totally overlap with preventive controls in the way you might think.
Is now the time to dump oPRPs or perhaps align them with the US definition of preventive controls? Do they still bring value considering it's still very much an ISO 22000 thing and only FSSC really ask for it?
Thoughts?
Personally, I never use the term oPRP. If you are recording something, be it a date, traceability code, quantity, then surely what you are recording is a pre-requisite.
Otherwise, why are you recording it?
I have to admit I always described oPRPs as for people who couldn't make up their minds. But I think it's valid to say that not all prerequisites are probably created equal, I'm just not sure that oPRPs help in that regard. Cleaning processes for one. I've had so many problems over the years with them yet they're not going down in anyone's HACCP plan as an oPRP as far as I've ever seen. Yet allergen online label verification or sieving probably yes. The former, yep, a big cause of recalls. I get that but if it's that much of a risk, why isn't it a CCP? Or if it's not that much of a risk (as some factories don't have them) why isn't it a prerequisite? The latter, I REALLY get no reason why making it an oPRP vs a CCP makes it better unless the only reason is that the site want to check it less often. And how is that a good thing?
I literally have an oprp because the auditor wanted to see one. Does it do anything for me? No, not really. Mine is a spec review on high risk ingredients. The issue? No company is going to send me a spec that says it contains a pathogen. They call you AFTER you've consumed said ingredient and tell you to recall it. IF they knew it contained a pathogen from the drop, they wouldn't ship it in the first place....lol. But we keep looking at all those specs! Just waiting for the day when one says the test results are bad! And my auditor is happy! So whatevs!
I literally have an oprp because the auditor wanted to see one. Does it do anything for me? No, not really. Mine is a spec review on high risk ingredients. The issue? No company is going to send me a spec that says it contains a pathogen. They call you AFTER you've consumed said ingredient and tell you to recall it. IF they knew it contained a pathogen from the drop, they wouldn't ship it in the first place....lol. But we keep looking at all those specs! Just waiting for the day when one says the test results are bad! And my auditor is happy! So whatevs!
A spec review? That is legitimately bonkers. How is that an oPRP? Mind blown...
I was reading the new Campden BRI standard and bless him, Andrew Collins has tried to square the circle and make oPRPs the same as Preventive Controls. Then call them something different.
Put it this way, I'm not sure it was worth the £145 I paid. Version 5 was far simpler. And all because ISO 22000 and the US decided to do something different.
There probably is a space for something between Prerequisites and CCPs. I'm just yet to be convinced oPRPs are that (or preventive controls for that matter, laughably, FDA "experts" I've talked to think all process preventive controls are CCPs which is just not true either.)
A spec review? That is legitimately bonkers. How is that an oPRP? Mind blown...
I was reading the new Campden BRI standard and bless him, Andrew Collins has tried to square the circle and make oPRPs the same as Preventive Controls. Then call them something different.
Put it this way, I'm not sure it was worth the £145 I paid. Version 5 was far simpler. And all because ISO 22000 and the US decided to do something different.
There probably is a space for something between Prerequisites and CCPs. I'm just yet to be convinced oPRPs are that (or preventive controls for that matter, laughably, FDA "experts" I've talked to think all process preventive controls are CCPs which is just not true either.)
Auditor literally said "You have to have an oprp of some sort, don't care what it is".....so we did this, and they checked the box. That's what a good deal of this is about imho.....checking boxes.
Auditor literally said "You have to have an oprp of some sort, don't care what it is".....so we did this, and they checked the box. That's what a good deal of this is about imho.....checking boxes.
GAAAAHHHH! That drives me nuts!
GAAAAHHHH! That drives me nuts!
OH yeah, just like the pirate with a ships wheel sticking out of his pants. Bartender says why is there a helms wheels sticking out of the top of your pants, and the Pirate says "arrrrrrr, it's drivin me nuts"........
What's a pirate's favourite letter?
(The person always replies "R")
No! It be the C they love!
Know why pirates are grumpy?
Because they arrrrrrrrrrrrrr
Okay, we could do this all day, lmao.....
I've actually been reading about pirates a lot lately. If you're so inclined pick up 'A general history of the pyrates', super amazing book.....