Hi Agleh and welcome to the forum.
Interesting questions.
Although I’m not a user of I22k myself, I can offer some comments to yr questions so that other actual users may freely criticise (preferably constructively ).
“Program”. Well, I22k defines PRP (3.8) as (food safety) basic conditions and activities that are necesssary ……. – This seems helpfully flexible.
However the format for the oPRP program has more exact required inclusions, see para7.5 (a-f) (sort of mini-CCP I guess).
A previous thread contained this (slightly shortened by me) description of PRP and oPRP which seemed quite useful IMO (credit Sonali) –
“PRP : These are basically the generic controls in any type of food buisness operation.. These are to be applied in all types of food buisness so as to maintain a hygienic environment to reduce the risk to the Food Safety .
Eg - Plant Layout or infrastructure control , pest control, personnel hygiene, sanitation , work environment.
PRP are foundation of HACCP .
oPRP : These differ from PRP in the sense that these are SPECIFIC to particular industry /food operations . And these are arrived only after doing the hazard analysis. So, oPRP wil differ within the food industry while PRP could be more or less similiar. Therefore, after you conduct hazard analysis for a specific food chain and there comes a requirement/step where control is required to prevent /reduce the hazard it becomes oPRP .
CCP : CCP also arrive as a result of Hazard Aanlysis but difference b/w oPRP & CCP is the risk level of the identified hazard. If the hazard pose very high risk to food safety then it is CCP rather than oPRP(substantial risk) .
Also, while doing hazard analysis some steps are required to control the hazard but since the hazard is reduced /eliminated in further step , it is not considered a CCP , so in such case it's an oPRP"
Since you have ‘done” HACCP already I guess you must already have compiled a set of procedures like SSOP typically derived from GMP, GAP etc. Depending on yr facility (eg see 7.2.2), I would hope the” procedures” in this to be similar to the desired “programs” for I22k”s PRP (“Maintenance and Infrastructure) but requiring further additions as per 7.2.3 maybe.
Regarding the choice as to the appropriate risk classification for CCP / oPRP, this may depend on the methodology within yr existing HACCP plan. One approach is illustrated here –
http://www.nordicinn..._img/heggum.pdf (pg 11)
Yr label question.
(Actually in some cases I have seen labeling as a CCP [eg for allergen or for reasons of traceability.] Currently it seems popular to put the former within HACCP prerequisite programs and separate the latter to itself.)
Auditors IMEX do not accept mislabelling other than allergenic related as a significant safety risk so IMO would not be an oPRP. Other people have any ideas on this ?
If you can justify otherwise, you need to satisfy para7.5 at a minimum.
“Validate sight check”? Devise a challenge test perhaps? Optician’s record.?
“Verification”? – Monitoring records ?? Maybe post-packaging sampling/checking? Complaints file?
Pls come back if more info required.
Rgds / Charles.C
Added – had some more thoughts about labelling.
After looking at link above, I realised that even the lowest risk was still designated as oPRP. I also noticed that 7.4.4 states that all control measures categorised as not belonging to the HACCP plan (ie non-CCPs) become oPRPS if they can be validated.(ISO2204/7.4.4). Life gets simpler, maaaybe. On this basis I change my opinion above to oPRP and wait for comments.
(I also realised that there are other situations where labelling can be a CCP, eg non-pasteurised fruit juices, specific expiry date situations.)