TQCSI Auditor Training “ISO 22000 - OPRPs vs HACCP”

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TQCSI Auditor Training

“ISO 22000 - OPRPs vs HACCP”

TQCSI Auditor Training

References

• ISO 22000:2005 Standard

• ISO 22004:2005 Guidance on application

• ISO 22003:2013 Auditor requirements

• WI 41 FSMS.

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Objective

• be aware of differences between ISO 22000 and HACCP

• not to describe how

• describe what is required.

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ISO 22000 - what is it?

• ISO 22000 provides elements of a food safety management system

• used for internal application, certification or contractual purposes, customer and regulatory requirements.

• aligns with ISO 9001+ HACCP Principles.

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Differences

• ISO 22000 vs ISO 9001

• Product realisation differences – HACCP vs ISO 22000 (Section 7)

• auditors need to be aware of differences between HACCP & ISO 22000.

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ISO 22000 at a glance

• Standard approach & common elements with ISO 9001

• terminology

• HACCP (GMP, CCP, CP)

• ISO 22000 (PRP, CCP, OPRP)

• no exclusions.

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ISO 22000

• food safety policy

• food safety objectives.

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ISO 22000

• FS Team responsibilities to plan to review system (system updating)

• FS Team requirement to evaluate verification results, verification activities, communication & the food safety management system at planned intervals.

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ISO 22000

• input & output requirements for FST meeting

• FSTM – MRM - FSTM.

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ISO 22000

• Food Safety Team Leader responsibilities

• Company to communicate internally to Food Safety Team.

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ISO 22000

External communication:

• food chain communication

• suppliers, contractors, consumers, regulatory and other organisations

• define responsibility/authority of personnel to communicate externally regarding food safety

• records of communication.

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ISO 22000

Internal communication:

•arrangements to communicate internally to personnel with impact on food safety

•Company to ensure Food Safety Team informed of changes list 5.6.2 (a-m).

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ISO 22000

• emergency preparedness & response – documented procedure and responsibilities

• a withdrawal exercise is required annually (mock food recall)

• the withdrawal does not have to involve an emergency response situation.

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ISO 22000

• pre-requisite programs (PRPs)

• control measures OPRPs & CCPs

• hazard analysis methodology/documents & records.

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PRPs

• Company must identify applicable PRPs

• PRPs manage basic conditions & activities

• selected for maintaining hygienic production/processing environment (eg programs - pest control, calibration, PM, sanitation, suppliers)

• not selected for controlling hazards to acceptable levels.

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PRPs

• PRPs applicable to products/processes should be identified, established & implemented

• extensive compared to HACCP (air, surrounding environment) - list 5.6.2

• procedure/instructions required to describe how managed.

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PRPs

• include in verification schedule

• records required for evidence of verification

eg if calibration is identified as a PRP, it should be in the verification schedule and a record of the verification for calibration available.

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Product Realisation (Section 7)

For each hazard in hazard analysis at each step:

• identify acceptable level of hazard in finished product

• consider statutory, regulatory, customer requirements, intended use

• result and justification recorded.

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Product Realisation (Section 7)

• for hazard analysis use ISO 22004:2005 (Figure 3 – Decision Tree)

• Decision Tree identifies when there are OPRPs & CCPs and refers to process of categorisation of control as an OPRP or CCP.

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Product Realisation (Section 7)

Codex Decision Tree identifies CCPs only - this is not to be used for classification of control measures for ISO 22000.

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Product Realisation (Section 7)

• for each hazard type, at each step, two questions must be considered and recorded

- referenced in Decision Tree (also documented in 7.4.3).

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Product Realisation (Section 7)

Food Safety Documentation:

Q1 - Is elimination or reduction of hazard essential to the production of a safe food?

Q2 - Is control of the hazard needed for defined acceptable levels to be met?

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Product Realisation (Section 7)

Record results:

• if answer is Y (some or all controls are OPRPs or CCPs).

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Product Realisation (Section 7)

Selection of Control Measures:

• select appropriate combination of control measures.

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Product Realisation (Section 7)

Validation of control measures:

• the control measures selected need to be validated to ensure the acceptable level of the hazard is achieved.

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Product Realisation (Section 7)

STEP INPUT HAZARD CAUSE Risk (High or Low)

Am

ount

pe

rmit

ted

in f

inal

pr

oduc

t ?

Is e

limin

atio

n /r

educ

tion

for

sa

fe f

ood

requ

ired

? Y

/N

Is c

ontr

ol o

f ha

zard

fo

r ac

cept

able

leve

ls

need

ed ?

Y/N

Control(s) measures

Controls include OPRP

or CCP

Y/N

Severity Likelihood

Overall

Storage Dry Goods Microbiological, Chemical, Physical, Quality

Infestation of product

Ineffective pest control, poor housekeeping

4 B 14 Nil N N PRP –pest control program in place.

PRP- Cleaning program.

N

Cooking Meat, vegetables, handling, cookers

Microbiological, Chemical, Physical, Quality

micro

Insufficient cooking of product.

2 C 8 As per FP specification

Y Y Cooking temperatures and times established & monitored.

PRP- Training

Y (OPRP/CCP)

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OPRPs –what are they?

• OPRPs are control measures deemed necessary to control hazards to acceptable levels (that haven’t been identified as CCPs)

• identified through ISO 22004 Decision Tree, including categorisation of elements (7.4.4 a-g).

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OPRPs –what are they ?

• there is no direct correlation between CPs under a HACCP Code & OPRPs in ISO 22000.

• the 22004 Decision Tree process must be used.

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CCPs

• control measures deemed necessary to control identified hazards to acceptable levels (and categorised as a CCP)

• identified through ISO 22004 Decision Tree & by the categorisation of elements (7.4.4 a-g).

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Product Realisation (Section 7)

• OPRP or CCP –??

• categorisation of controls by assessment of

items listed 7.4.4 a-g.

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Product Realisation (Section 7)

• record of the assessment is required to demonstrate 7.4.4 a-g considered to distinguish control as OPRP or CCP

• methodology must be documented in procedure (“logical approach”- up to client).

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Product Realisation (Section 7)

• OPRP vs CCP categorisation examples provided in ISO 22004 Guidelines.

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Product Realisation (Section 7)

AGAIN - the CODEX Decision Tree is not to be used!!

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Categorisation of controls (7.4.4)

• a) its effect on identified food safety hazards relative to the strictness applied

• b) its feasibility for monitoring

• c) its place within the system relative to other control measures

• d) the likelihood of failure in the functioning of a control measure/processing variability;

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Product Realisation (Section 7)

• e) the severity of the consequence(s) in the case of failure in its functioning

• f) whether the control measure is specifically established and applied to eliminate or significantly reduce the level of hazard(s)

• g) synergistic effects (ie interaction between two or more measures results in combined).

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Product Realisation (Section 7)

STEP/ Control Measure

Using 7.4.4 a-g

To identify controls as CCP or OPRP

Status CCP/OPRP & reason

Validation of CCP Limits

a b c d e f g

Goods receival/ Temperature

inspections for goods received.

yes Yes-on receival

Yes-last control

Not likely high Y N CCP-control specific, monitoring in real time, last step for control.

FSANZ

Goods receival/ Product

inspection

yes Yes-on receival

Would be

checked at

further steps

possible low Y N OPRP- would be detected further down process

N/A

Cooking/Cooking Time/Temp &

monitoring

yes yes Last control

possible high Y N CCP- last step, significance of failure

FSANZ

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Product Realisation (Section 7)

• a HACCP plan is required to describe CCPs and their controls.

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Product Realisation (Section 7)

• an OPRP Plan is required for OPRPs and controls

• critical limits are not required for OPRPs (generally specifications).

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Product Realisation (Section 7)

• both OPRP and CCP monitoring records require evidence of review by designated person, with knowledge and authority to initiate corrective action.

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Product Realisation (Section 7)

Verification Planning:

• documented verification plan for verification activities

• activities to confirm PRP, OPRPs, CCPs implemented and effective

• hazard analysis kept updated

• hazard levels within acceptable limits.

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Product Realisation (Section 7)

Verification Planning:

• other procedures implemented and effective

• verification results to be recorded & communicated to the FST.

JLB - Lead Auditor Course - Module FS - # 42

ISO 22000 Information Worksheet

ISO 22000 Flow Chart (*)

ISO 22000 Hazard Worksheet

ISO 22000 CCP/OPRP Worksheet

ISO 22000 Decision Tree

ISO 22000 HACCP/OPRP Table (*)

Verification Schedule.

Typical ISO 22000 Documentation

JLB - Lead Auditor Course - Module FS - # 43

For clients certified to both Systems:

• ISO 22000 requirements override HACCP requirements

• ISO 22000 will also meet HACCP requirements

• ISO 22000 requirements must apply to all operations

• ISO 22000 methodology to be followed.

ISO 22000 + HACCP Certification

JLB - Lead Auditor Course - Module FS - # 44

For clients certified to both Systems:

• use of ISO 22004 decision tree only

• categorisation of all controls must meet ISO 22000, Clause 7.4.4 requirements

• expect to see use of ISO 22000 records only

• do not expect to see any CPs

• expect to have PRPs, OPRPs & CCPs.

ISO 22000 + HACCP Auditing

JLB - Lead Auditor Course - Module FS - # 45

• audit using ISO 22000 methodology & requirements will meet HACCP requirements

• audit using HACCP methodology WILL NOT meet ISO 22000 requirements.

ISO 22000 vs HACCP Auditing

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ISO 22000 Audit Report

Report to include requirements of ISO17021 including:

•information about PRPs used by organisation

•hazard analysis methodology

•comments on the Food Safety Team

•other relevant issues.

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TQCSI

Thank you!

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