28 replies to this topic

[PedroP]

Hello

I have a doubt about PRP or CCP??

The question is if I should consider the metal detector proccess as a CCP or as PRP operative?

What do you think??

It is different the treatment as a PRP or as a CCP!!

Have you have any experience in your audits??

Thanks all of you.

Pedro Pablo (Spain)

[PedroP]

Hello again!!

How should I categorize the metal detection control measure as operational PRPs or in HACCP plan??

What do you think??

Thanks

Pedro Pablo

[cazyncymru]

Hello

I have a doubt about PRP or CCP??

The question is if I should consider the metal detector proccess as a CCP or as PRP operative?

What do you think??

It is different the treatment as a PRP or as a CCP!!

Have you have any experience in your audits??

Thanks all of you.

Pedro Pablo (Spain)

A Loaded Question Pedro!

I would need to look at the process in full in order to make the decision, but as a rule of thumb i would say that if you needed to employ the use of a metal detector then i would put it in as a CCP (to be on the safe side, assuming checking it regular etc)

Others may tell you differently, personally i don't have any metal detectors so its not an issue for me

[moo73steve]

For us, it was a CCP and then we downgraded it to a PRP based on a history without any issues, i.e the likelihood was deemed to be lower based on history so as to drop it below our limit based on the risk assessment.

So I guess it may depend on what history you have to back up your assessment. For me the significance is unlikely to change but the likelihood may over time.

Best of luck.

Steve

[Suzuki]

Dear Pedro,
Interesting subject. The timing cannot be just right as I was having a bowl of muesli cereals with milk and guess what I found in it ... a piece of metal measuring approximately 3mm x 5 mm and fortunately for me I was munching my meals very slowly and was able to salvage my teeth from severe damage

It was a product imported from the EU and purchased from a member of the BRC.

Dear Steve,
So should we be prepared to down grade our CCP to an OPRP because we have no historical event that would suggest that such a risk exposure is "we feel" may not likely to occur. Perhaps, I would consider a downgrade if you have magnets upfront the process lines which makes your metal detector purely a validation step rather than a kill step. Would you re-assess your control measure status base on what i had just gone through and I am sure the metal piece was not intentional placed in the product as well but appeared rather to be a broken equipment part.

Dear Cazy
I am in common view with you that it is not possible to give an advice base on general information.

Regards
Suzuki

[PedroP]

Thanks for your advices

I know that the question was so general.

The company is a poultry manufacturer who produce fresh, frozen and cooked chicken products and roast chickens. They have had problems which metal elements and pieces in fresh products (historic problems), due to problems with blades and repairs in the building. But they have now a high-sensitivity metal detector and magnets.

Like you said it is necesary check the likehood to ocur and the historic.

Thanks again

Pedro (SPAIN)

[moo73steve]

Dear Steve,
So should we be prepared to down grade our CCP to an OPRP because we have no historical event that would suggest that such a risk exposure is "we feel" may not likely to occur. Perhaps, I would consider a downgrade if you have magnets upfront the process lines which makes your metal detector purely a validation step rather than a kill step. Would you re-assess your control measure status base on what i had just gone through and I am sure the metal piece was not intentional placed in the product as well but appeared rather to be a broken equipment part.

Dear Suzuki,

Keeping emotions aside, I think it is reasonable to review all CPs & CCPs according to a risk matrix on a regular basis, against significance and likelihood (or some other method). So if a complaint was received that altered information used in a review than logically the outcome would change based on the new information. Just remember that even if something is not a CCP anymore, it does not mean you will automatically monitor it any differently from if it was a CCP.

Thanks
Steve

[Penard]

Just to illustrate Steve's opinion you have to be very carefully about changing a CCP. To my mind, a CCP depends on a lot of things.

For instance you can have 1 or 2 years without a metal piece in your cooked meat - and no consumer complaint.
The third year, you decide to stop the monitoring of your CCP because you think after your revision that's ok. The observation of your oPrP decreases; if someone discovers a metal piece in your product because of a lot of things - raw materials, difficulties during the process...how can you explain it to the consumer, and how can you explain it to the news - so extrem, but it can exist! You can always have a risk!
For sure if you continue to work all along the process, you choose your suppliers, with accurate demands, and you improve the level of your raw materials, the abilities of your suppliers, that's the good way to change your CCP into a oPrP - easier to talk about than to do it...
That is a very sensitive issue, and I am not sure our explanations would quiet everybody.

Moreover, I think it's easier to change a microbiological CCP into a oPrP than a foreign body (but it's another issue).

Consequently, I think you have some critical points to think of, but you have to consider people opinion too...and that is not easy at all!!!

That's just my opinion, sorry for my english if I am not clear enough! But it was such an interesting question I want to answer,

Emmanuel.

[Bobby]

"The company is a poultry manufacturer who produce fresh, frozen and cooked chicken products and roast chickens. They have had problems which metal elements and pieces in fresh products (historic problems), due to problems with blades and repairs in the building. But they have now a high-sensitivity metal detector and magnets.

Like you said it is necesary check the likehood to ocur and the historic."

Pedro,
I am surprised to see that the company has invested on a High sensitivity metal detector, but not bothered to keep the building in good repair.
You are letting your product get contaminated and then you are trying to establish a control by tracing the contaminant.

ISO 22000 and HACCP cannot be effectively implemented if pre-requisites are not met.

Have you had any complaints after you placed the metal detector?

Bobby Krishna
Food Inspector
Dubai

[Simon]

Monda morning BUMP.

[Charles.C]

Dear All,

I had to use Google to find out what BUMP means. (an added time span note and xlinks were also suggested but I guess that would have defeated the reason here )

I realise this is a bit escapist but surely it's easier to classify metal detection (the last one that is) as CCP since there are so many readily available xreferences in the literature . The true status as suggested above may be variable depending on the process etc but sometimes simplicity is the best result (particularly if it's conservative also) and I'm sure a typical auditor will be so happy to avoid arguments.

The subsequent cost of a metal detector is a different issue of course .

Rgds / Charles.C

[Gaskit]

Dear Charles,

I agree on all except one point:

Arguing with an Auditor; is like wrestling with a pig in muck! Eventually you get to realise that the pig enjoys it (think I read it on one of the discussion pages, maybe Brian quoted it).

LOL, regards,

Steve

[downtown]

Dear Steve,

I am as an auditor agree with your opinion about not arguing with an auditor. Your example fits perfectly. It smiled me so much . Can I use it in my audits ? Thanks.

By the way, I would like to open an other discussion about metal detectors :

There is an irony for this subject.
Some companies do not prefer to buy any metal detector or their working environment or technology is not suitable for employing it. If they can explain why they didn't do , they will have no problem in the audit. Because even BRC and IFS standards require the company shall decide need for detector by an appropriate hazard analysis.

However, when they make investment and spend thousands of dollars for this, they might probably face with a headache. Malfunction of metal detector during the audit (missing test particle or forgetting to reject products contaminated by purpose.) or any missing corrective action or operation records.

And my answer to the very first question :

- a general thing : I recommend to stay away from operational pre-requisite programs. This term I think will not be used as universal as PRP or CCP and when you decide to go with other certification schemes, you might suffer problems with unexperienced auditors. No international or national laws refer to this term. Even ISO 22000 itself is not explanatory about it.

Let me tell a quote from Einstein : If you can not explain an idea to a teenager, it means that you didn't understand it enough.

- It is obvious that if a metal detector is correctly positioned (at the end and after packaging), it is a CCP. Not a PRP.

- If combined with magnets at different locations in flow, Measure coming last is CCP. Others are PRP.

Kara

Edited by downtown, 22 October 2007 - 08:41 PM.

[jose22000]

In my opinion, if you are determined that the risk of contamination by metal bodies is high and the likelyhood of occurrence is also high you must to put a metal detector correctly at the end of your production line. Since this step (metal bodies detector) is unneccesary for the production of food but it's important to prevent contamination of food you have to appoint this as a CCP.

Saludos compañero!

[Charles Chew]

- a general thing : I recommend to stay away from operational pre-requisite programs. This term I think will not be used as universal as PRP or CCP and when you decide to go with other certification schemes, you might suffer problems with unexperienced auditors. No international or national laws refer to this term. Even ISO 22000 itself is not explanatory about it.

Dear Downtown,

ISO 22000 is widely accepted as a foremost FSM System including having been adopted by numerous countries as their own national standard. Your remarks appear to differ the view that even Turkey is embracing ISO 22000 in a fairly big way as most CBs have offices in that part of the region. As a matter fact, it would be interesting to know which FSM program or system that you subscribe to.

Furthermore you mentioned that you are an auditor - are you QMS or FSMS? BTW, I also always encourage debates with Food Auditors as often Auditors have often been found to misinterpret the requirements or situations incorrectly. If such dialogues are not tolerated, the Auditor should be replaced.

Regards
Charles Chew

[Charles.C]

Dear All,

I certainly wouldn’t (dare ) challenge CharlesChew’s comments but I have to applaud “Downtown” for his willingness to comment on the auditing difficulty regarding interpretation of oprps. Would be interested to know how he makes such assessment in his own case?

Regards / Charles.C

[downtown]

Dear Charles,

There is a misunderstanding about my comments. I am not opposite of ISO 22000. I was talking about the term OPRP was not as common as PRP or CCP. This term is referred by only ISO 22000 and ISO 22000 is not explanatory enough about OPRP. I have understand the meaning of this term by myself hardly. But I haven't yet understand why such a new term has been created despite presence of sufficient number of terms as defined by food codex alimentarius (WHO/FAO) and in EU Food law :178/2002. IFS and BRC standards (even 5th versions) are excluding this term.(OPRP)

On the other hand, if a company determines a particular process step is very very important for ensuring food safety, and takes necessary measures, doing determined monitoring and acting according to nature of of failures and recording and verifiying, Do you think it does matter to name this point as CCP or OPRP?

And... let us not forget that ISO 22000 is a very new standard and needs some improvements obviously. Please have a look at following links.
http://www.ciesnet.c....foodsafety.asp

http://www.ciesnet.c.....mber 2007.pdf

and what is ISO 22000 link?
http://www.ciesnet.c.....mber 2007.pdf

and have a look at the members of GFSI board :
http://www.ciesnet.c...ifoundboard.asp



I am both a QMS and a FSMS auditor. But please remember, in order to become an auditor you have to have a professional experience in related sectors in your past life. I mean we weren't born as auditors. So I can tell you that I have wrestled with this type of auditors as an auditee.

Thanks for your comments. I hope I have expressed myself better.

Kindest regards.

Kara

[Charles Chew]

Dear Kara,

Being very involved in ISO 22000 both in facilitation and certification, I find the requirements of the reference standard extremely demanding. While differing in opinion on the requirements of private standards under the GFSI umbrella if compared to ISO 22000 (the other way round) appear to be on similar level of demand but IMO, is still a shade off ISO 22000 if truly understood. However, I must stress here IMO that most BRCs and IFS in the EU are operated at very high level of standards because of the excellent auditors there.

OPRP is nothing more than just verification activities that are implemented to demonstrate the effectiveness of your individual PRPs while collectively would provide a dynamic view of the overall FSMS Verification.

IMO, the recent statement raised by GFSI comparing between ISO 22000 and GFSI recognized private standards, appear to suggest a backdrop that there may be some form of compromise towards mutual recognition soon. It is also my personal view that the international growth of ISO 22000 would happen in the Far East esp. Japan, China and India etc which is likely to benchmark the future of GFSI or ISO 22000.

Regardless of which standard a Company embraces, 2nd Party Audits are almost always a necessity to validate the effectiveness of the specific FSMS that are in place. I hope Turkey would go all out for ISO 22000 as it is becoming pretty well accepted in that part of the world particularly on the hospitality segment

Regards
Charles Chew

Edited by Charles Chew, 02 November 2007 - 07:54 AM.

[downtown]

I propose to open a new discussion about ISO 22000 thus we can exchange our opinions easier.

[Charles Chew]

I propose to open a new discussion about ISO 22000 thus we can exchange our opinions easier

Hi Kara,

There is no need to open another forum as this is "the forum". You may want to refer to previously discussed subject on the interpretations and issues of PRPs and OPRPs under ISO 22000 which are really very useful. As a matter of fact, when we debate and discuss about metal detector, we are already on the subject of PRP facilitation.

Regards
Charles

[downtown]

No no. Of course, we can continue from this topic. However, I would like to discuss issues related to HACCP and ISO 22000 in a different way by opening a new topic.

I propose to open a new discussion about ISO 22000 thus we can exchange our opinions easier

Hi Kara,

There is no need to open another forum as this is "the forum". You may want to refer to previously discussed subject on the interpretations and issues of PRPs and OPRPs under ISO 22000 which are really very useful. As a matter of fact, when we debate and discuss about metal detector, we are already on the subject of PRP facilitation.

Regards
Charles

[Simon]

No no. Of course, we can continue from this topic. However, I would like to discuss issues related to HACCP and ISO 22000 in a different way by opening a new topic.

Feel free to start a new topic Downtown. If you are not sure how let me know.

Regards,
Simon

[Witch]

To get back to the initial question: I am missing the risk analysis in your answers!
If there is a risk with metal, the metal detection has to be a CCP. If there is a detection limit and the metal pieces falling through are still so big that they can cause damage, the metal detector reduces the risk and should be a PRP. It moderates the problem, but does´not solve it!
For that case you have to find something else to get rid of metal!
Thats it!

Andrea

[Charles.C]

Dear Andrea,

Speaking as an I22k peasant, could I ask -

I think I agree with yr metal logic but when you say

should be a PRP

, do you mean oPRP ??, I thought PRP's were restricted to hygiene and closely related issues.
Definitely not but stil interested.

Rgds / Charles.C

[downtown]

Dear Charles and Andrea,

I would like to add one of my examples for PRP and OPRP. I try to make an analogy .

Hand hygiene is a PRP universally at all food industries at any stage. However, In preparation of cold sandwiches by hand is I think an OPRP since there is no heat processing stage at this process. This stage is as critical as a CCP but due to lack of a critical limit it is considered to be an OPRP.

We can make an analogy for this.

All measures taken against metal contamination is PRP universally at any stage at any food sector. If any stage is the last chance to catch metal introduction, this stage is aimed to be at least critical. (CCP or OPRP question is a little bit ambigious). All critical limits put here (size of test particle / 3 mm-5mm) are for verification purposes not for monitoring.

regards

downtown

Dear Andrea,

Speaking as an I22k peasant, could I ask -

I think I agree with yr metal logic but when you say , do you mean oPRP ??, I thought PRP's were restricted to hygiene and closely related issues.
Definitely not but stil interested.

Rgds / Charles.C