OPRP or HACCP Plan - Opinions and Practical Example Wanted

[Stijloor]

Well, #2 was a good comment and i grateful for that, but it was not actually an answer to my question.

Sometimes, by reducing the text and asking very specific questions, perhaps one at a time, may get you more responses. Remember that most Members here have limited time and a long posts may not always get the attention of our Members.

Nobody will be ignored, and one of our jobs as Moderators is to ensure that no posts are left unanswered.

Keep posting.

Stijloor, Forum Moderator.

 

[harry]

Hello!

One of the examples I’ve heard a lot of times to understand difference between operational PRP and HACCP plan is example with metal detector. Last metal detector on the production line is a CCP and managed by HACCP plan and all other metal detectors are not CCP and managed by operational PRPs. ..................

Yes, the last one is critical because you have nothing to fall back to after that.

In practice we don’t have any difference in managing all these metal detectors, we check them let’s say every 2 hr with the same samples (same critical limits), corrective actions are also the same.

The degree of control should be dependent on risk. Is the degree of control for the CCP in line with the risk involved? Some people choose to have the same set of controls just like you but have a stronger magnet (gauss) for the CCP. There is also nothing wrong if you extend the same set of control for the CCP to the oPRPs but if you have good history, you may want to look into relaxing control of the oPRPs. On the surface, I would agree that you only need metal detection at the CCP but without a knowledge of how your processes are set up, I can't really tell.

ISO 22000 doesn’t require critical limits for operational PRP

Sure, because it is dependent on an individual organization's industry and process set up and results of risk analysis. Finally, on the amount of risk you are comfortable with.

 

[6thsense]

hI Covers. Just had an audit lately hence the small absence. ISO 22000 requires that you identify CCPs and OPRPs. I have been having issues with this myself as my boss has other views regarding whats an OPRP. I attach some examples I got from some friends of mine. I work for a Bottling Company so the examples I have mostly revolve from this world. Hope this helps the discussion.

 

[Bilijaf]

Hi 6th Sense,
I dont know which questions are you using for CCP discussion, we use usually the attached CCP Decision tree, where if Q1 answer is yes, Q2 answer is also yes, than it is a CCP.

 

[6thsense]

I attach our Decision Trees

 

[Sveta]

Hi 6thsense!
Thanks for your information.
I looked at your decision tree, but don't see how you determine oPRP, can see only CCPs?
In your oPRP table you have critical limits which are not required for oPRP. Why do you decide to include critical limits into oPRP?
Thanks!

 

[6thsense]

Sveta, been busy sorry for the late reply. oPRPs are deduced at any point within the process for situations were we have a potential CCP but a PRP exists to control the hazard.
Regarding the Critical limits our processes already have set limits for example the microbiological specifications for bottles <25cfu/bottle, we just included it when documenting the oPRPs.

 

[diaspar]

Hope that delayed contributions are permissible.

Regarding the original question, the necessity of using an oprp as a control program is fundamentally stated in def.3.9 where “likelihood” is logically interpreted (somehow) in a risk-based fashion. The additional word “essential” can hopefully be interpreted as assisting the (somehow). The “essential” can then be (partially) interpreted as referring to the detailed hazard analysis procedure prescribed in 7.4.1 – 7.4.4 culminating in selection of a cut-off into oprp-ccp / (the rest). This process has analogies to traditional haccp (TH) although the implemented hazard analysis for oprp is typically less scope-restricted to the production flowchart than TH.

IMO it is a subjective choice as to how you evaluate (both conceptually and quantitatively) the necessity / capability of the individual metal detectors (MD) to handle the perceived risk. As previously noted in this thread the choice demands information. If the MDs are all assumed identically effective, presumably only one fully functional unit is required to do the job (?). This could theoretically be any of the units. I think traditional haccp often chose to evaluate an arbitrary "worse case" scenario with at least the “last one standing”. The risk analyses for individual prior units could then be assessed (adjusted) appropriately. For ISO 22000, it should be easier (particularly from a paperwork perspective) to simply classify this series (ie not parallel) as a combination of only one Met.D. I believe this is auditorially acceptable despite (?) not appearing explicitly in ISO 22000.

As far as the method of categorisation is concerned, one might say that, for implementation, subjectivity rules and is (rightly or wrongly) implicitly supported by ISO 22004. Presumably, if one wishes to minimise the chance of auditorial argument it is safer to follow a procedure involving all of 7.4.4 (a-g) although many re-interpretations / simplifications are evidently considered acceptable by their appearance in the literature.

I have also occasionally seen mention of oprps being given specific critical limits on the basis of “there is no (auditorial) risk in expansion of the standards requirements”. Not so sure about that one. Obviously one can always re-label anyway if desired, similar to “operational limits’ in trad.haccp