TQCSI Auditor Training “ISO 22000 - OPRPs vs HACCP” References • ISO 22000:2005 Standard • ISO 22004:2005 Guidance on application • ISO 22003:2013 Auditor requirements • WI 41 FSMS. TQCSI Auditor Training Objective • be aware of differences between ISO 22000 and HACCP • not to describe how • describe what is required. TQCSI Auditor Training 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. TQCSI Auditor Training 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. TQCSI Auditor Training ISO 22000 at a glance • Standard approach & common elements with ISO 9001 • terminology • HACCP (GMP, CCP, CP) • ISO 22000 (PRP, CCP, OPRP) • no exclusions. TQCSI Auditor Training ISO 22000 • food safety policy • food safety objectives. TQCSI Auditor Training 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. TQCSI Auditor Training ISO 22000 • input & output requirements for FST meeting • FSTM – MRM - FSTM. TQCSI Auditor Training ISO 22000 • Food Safety Team Leader responsibilities • Company to communicate internally to Food Safety Team. TQCSI Auditor Training 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. TQCSI Auditor Training 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). TQCSI Auditor Training 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. TQCSI Auditor Training ISO 22000 • pre-requisite programs (PRPs) • control measures OPRPs & CCPs • hazard analysis methodology/documents & records. TQCSI Auditor Training 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. TQCSI Auditor Training 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. TQCSI Auditor Training 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. TQCSI Auditor Training 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. TQCSI Auditor Training 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. TQCSI Auditor Training Product Realisation (Section 7) Codex Decision Tree identifies CCPs only - this is not to be used for classification of control measures for ISO 22000. TQCSI Auditor Training 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). TQCSI Auditor Training 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? TQCSI Auditor Training Product Realisation (Section 7) Record results: • if answer is Y (some or all controls are OPRPs or CCPs). TQCSI Auditor Training Product Realisation (Section 7) Selection of Control Measures: • select appropriate combination of control measures. TQCSI Auditor Training 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. TQCSI Auditor Training Dry Goods HAZARD Microbiological , Chemical, Physical, Quality Infestation of product Cooking Meat, vegetables, handling, cookers Microbiological , Chemical, Physical, Quality CAUSE Ineffective pest control, poor housekeeping Risk (High or Low) Severity Likeli hood Overall 4 B 14 Nil N Is control of hazard for acceptable levels needed ? Y/N Storage INPUT Is elimination /reduction for safe food required? Y/N STEP Amount permitted in final product ? Product Realisation (Section 7) Control(s) measures N PRP –pest control program in place. Controls include OPRP or CCP Y/N N PRP- Cleaning program. Insufficient cooking of product. micro 2 C 8 As per FP specification Y Y Cooking temperatures and times established & monitored. PRP- Training TQCSI Auditor Training Y (OPRP/CCP) 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). TQCSI Auditor Training 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. TQCSI Auditor Training 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). TQCSI Auditor Training Product Realisation (Section 7) • OPRP or CCP –?? • categorisation of controls by assessment of items listed 7.4.4 a-g. TQCSI Auditor Training 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). TQCSI Auditor Training Product Realisation (Section 7) • OPRP vs CCP categorisation examples provided in ISO 22004 Guidelines. TQCSI Auditor Training Product Realisation (Section 7) AGAIN - the CODEX Decision Tree is not to be used!! TQCSI Auditor Training 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; TQCSI Auditor Training 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). TQCSI Auditor Training Product Realisation (Section 7) STEP/ Control Measure Using 7.4.4 a-g To identify controls as CCP or OPRP a Goods receival/ Temperature inspections for goods received. Goods receival/ Product inspection Cooking/Cooking Time/Temp & monitoring Status CCP/OPRP & reason b c d e f g yes Yes-on Yes-last Not likely receival control high Y N CCP-control specific, monitoring in real time, last step for control. yes Yes-on receival Would possible be checked at further steps low Y N OPRP- would be detected further down process yes yes Last control high Y N CCP- last step, significance of failure TQCSI Auditor Training possible Validation of CCP Limits FSANZ N/A FSANZ Product Realisation (Section 7) • a HACCP plan is required to describe CCPs and their controls. TQCSI Auditor Training Product Realisation (Section 7) • an OPRP Plan is required for OPRPs and controls • critical limits are not required for OPRPs (generally specifications). TQCSI Auditor Training 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. TQCSI Auditor Training 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. TQCSI Auditor Training Product Realisation (Section 7) Verification Planning: • other procedures implemented and effective • verification results to be recorded & communicated to the FST. TQCSI Auditor Training Typical ISO 22000 Documentation 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. JLB - Lead Auditor Course - Module FS - # 42 ISO 22000 + HACCP Certification 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. JLB - Lead Auditor Course - Module FS - # 43 ISO 22000 + HACCP Auditing 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. JLB - Lead Auditor Course - Module FS - # 44 ISO 22000 vs HACCP Auditing • audit using ISO 22000 methodology & requirements will meet HACCP requirements • audit using HACCP methodology WILL NOT meet ISO 22000 requirements. JLB - Lead Auditor Course - Module FS - # 45 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. TQCSI Auditor Training TQCSI Thank you! TQCSI Auditor Training