FSSC contradiciton from HACCP
Title meant to say:
*FSSC contradiction from Codex
(Not HACCP)
I'm trying to understand some nuance here.
Say I have a Medium SOE and Medium LOO in my Hazard Analysis. That means it's a significant hazard.
But then I have my PRPs, which reduces the LOO to Low.
Does it still need an OPRP, or do I call the PRP(s) reducing that Likelihood to a Low an OPRP?
This would be following the Codex decision tree, where you basically have an initial LOO and a residual LOO. Is that alright in the context of FSSC?
Hi T-N,
:welcome:
Welcome to the IFSQN forums.
I think I would consider this on an individual and specific basis for each case, but in theory the reduction in likelihood by the PRP can mean that the hazard is not significant and does not need to be part of the Hazard control plan (HACCP/OPRP plan).
You confirm your PRPs as part of your preliminary information and then consider that information when you conduct the hazard analysis. If your PRP is reducing the significance of your hazard to an acceptable level then I would expect you to ensure that you have proportionate monitoring and verification of that PRP to ensure it is indeed controlling the hazard adequately.
Relevant info from ISO 22000: 2018 Food safety management systems — Requirements for any organization in the food chain:
8.5.1.5.3 Description of processes and process environment
The food safety team shall describe, to the extent needed to conduct the hazard analysis:
a)…
c) existing PRPs, process parameters, control measures (if any) and/or the strictness with which they are applied, or procedures that can influence food safety;
….
8.5.2 Hazard analysis
8.5.2.1 General
The food safety team shall conduct a hazard analysis, based on the preliminary information, to determine the hazards that need to be controlled. The degree of control shall ensure food safety and, where appropriate, a combination of control measures shall be used.
8.5.2.3 Hazard assessment
The organization shall conduct, for each identified food safety hazard, a hazard assessment to determine whether its prevention or reduction to an acceptable level is essential.
The organization shall evaluate each food safety hazard with regard to:
a)the likelihood of its occurrence in the end product prior to application of control measures;
b)the severity of its adverse health effects in relation to the intended use (see 8.5.1.4).
The organization shall identify any significant food safety hazards.
The methodology used shall be described, and the result of the hazard assessment shall be maintained as documented information.
Kind regards,
Tony
FSMA and preventive controls changed a lot of the thinking on this and muddied the waters. Some HACCP training books now will state that oPRPs and CCPs combined are the same as preventive controls. They're not.
For US plants, you should only apply your GHPs before doing your risk assessment. Elsewhere in the world you can apply your PRPs first.
But there is a good reason (before the FDA came along) that global standards did this. It's because without it, you end up with far too many CCPs and things that can't really be monitored.
To my mind, as long as you can justify your decision, it's valid. And there are decision trees out there which can help.
But whether FSMA and a differing approach should have muddied these waters is an interesting question to me. If you take a step back and ask the question... "have CCPs and oPRPs actually made food safer?"
In comparison with make then test which was the approach before? Yes, for sure.
But look through the reasons for recall. Are most of them due to CCP failures or PRP failures where PRPs are controlling significant hazards...