What are Prerequisite Programmes?
Prerequisite programmes (PRPs) set the foundation for the “successful application and implementation of the HACCP system”1. They can be applied generally at any step within the food chain from primary production to handling of the final product1. Prerequisites are fundamental practices and procedures that provide “basic environmental and operating conditions” necessary for the provision of safe food and drink4.Common prerequisite programmes include Good Hygiene Practices (GHP), Good Agricultural Practical (GAP) and Good Manufacturing Practices (GMP)1. Internationally recognised standards for PRPs can be found in the Codex Alimentarius General Principles of Food Hygiene. UK and European Union law is closely aligned with this document. Certain GHPs could also be “considered as control measures applied at CCPs in the HACCP system”, such as temperature and time control and product formulation at specific steps in the process 1.
Correctly implemented PRP’s may be all that is required to control hazards in a low-risk business where there is no preparation, manufacturing or processing of food1. Although, it might be “necessary to place greater attention on some GHPs that are particularly important for food safety”, such as cleaning and disinfection4. If application of GHPs is not sufficient, then a “combination of GHPs and additional control measures” at critical control points (CCPs) should be applied1. This could occur due to the “complexity of the operation” and/or “specific hazards” associated with the product, process or end use of the product1.
Established PRPs may not comply with sector specific legislation and codes of practice. Reviewing appropriate sources of information is helpful in identifying any gaps in existing standards. Reference documentation can include published regulatory requirements, technical guidance produced by competent authorities and customer and/or certification scheme codes of practice1.
Validation, Monitoring and Verification
The successful application and implementation of the HACCP system requires “well-established” and “fully operational” PRPs that are validated, documented, monitored and/or verified1.
Validation is about obtaining evidence that PRPs are effective in controlling hazards. This scientific and technical information can be found in technical guides, published scientific literature, and by conducting pre-production trials.
Monitoring is important because it can identify if a specific PRP standard has been achieved or not. This provides an opportunity to intervene when a deviation occurs and take appropriate action to regain control. Monitoring activities for PRPs should be recorded to support verification of the HACCP system and if required a due diligence defence in court.
Verification activities, in addition to monitoring, demonstrates PRPs are working in accordance with documented set standards. These activities include compliance audits, conducting tests (physical, chemical and/or microbiological), and reviewing documents and records. They should be completed by someone internally who does not conduct day to day monitoring, such as supervisor or manager, or externally by a competent auditor. Persons conducting verification activities must not verify their own work.
What are Operational Prerequisite Programmes?
Operational prerequisite programmes (OPRPs) are a requirement for FSSC 22000 and sit in between prerequisite programmes (PRPs) and critical control points (CCPs). These activities control hazards at a specific process step as opposed to PRPs which generally manage them across the entire food
operation. OPRPs are identified in the hazard analysis as essential control measures in preventing contamination in products or in the process environment, for example targeted cleaning of a shared production line. They can also be classified as control measures where continuously monitoring or setting observable critical limits are difficult to achieve. Confusion can arise in the identification and justification for an OPRP. A decision tree is a useful tool that can help determine whether a specific hazard identified during the hazard analysis is controlled by a PRP, OPRP or CCP. Campden BRI have produced a simple to use decision tree (HACCP: a practical guide). The decision and justification for an OPRP must be recorded.
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