OPRP vs CCP Glass Contamination
I'm so old OPRPs weren't a thing when I started doing HACCP plans :)
However, I'm working on a HACCP plan for bottling alcoholic beverages (spirits - whisky, rum, vodka).
Using our Corporate Tech Services decision tree is leading me to a quandary. I've always considered the risk of glass contamination as a CCP
but our process to control this hazard is to monitor the air and water cleaning lines (depending on which line the product is running on) to ensure the pressure is within specification
and to visually inspect that the air/water cleaning equipment is working appropriately. (Empty Bottles are manually dumped from cases and then inverted and either air or water washed before being filled)
the question in our Decision Tree says " Is the frequency of monitoring/checking the control measure sufficient to enable immediate corrective action? If yes, CCP, if no OPRP.
As we do not have any sort of immediate way to tell (eg no alarms to alert if the pressure should drop below spec) , we have containment and rework procedures to deal with an eventuality of finding that the control has broken down between the hourly checks.
So, in that case, is it an OPRP - despite the fact that glass contamination is critical?
Sorry if this sounds a ridiculous question.
Eventually we will want to certify this to FSC22000 standard, but we've a ways to go yet.
Is the frequency of monitoring/checking the control measure sufficient to enable immediate corrective action If Yes, - CCP, If No - OPRP
ran a glass jarred product at PP. Only visual inspections and we recorded the #jars that broke during the process
If a jar broke in the wash sink water was dumped and sink wash/rinsed prior to refill
SQF though not FSC
By bigger concern would be testing the air that your using to flush the bottles to ensure your not filling them with micro or yeast/mold
Since this step(s) is manual---your frequency is with each unit hence no risk
According to ISO 22000:2018:
A CCP is a control step in the process with a measurement. You have a critical limit: time, temp, pH, size, etc.
An OPRP is a control step in the process with a measurement or observation. There is no critical limit beyond a type of yes/no question: visual checks, present/absent, intact, etc.
Therefore, if the step is to ensure the glass is intact, that would be an OPRP.
"Is the frequency of monitoring/checking the control measure sufficient to enable immediate corrective action? If yes, CCP, if no OPRP"
The above is not an appropriate question for determining CCP/OPRP. Monitoring frequency is more related to the acceptable scope of an issue the company is willing to accept and they should both have a sufficient monitoring frequency.
I'm so old OPRPs weren't a thing when I started doing HACCP plans :)
However, I'm working on a HACCP plan for bottling alcoholic beverages (spirits - whisky, rum, vodka).
Using our Corporate Tech Services decision tree is leading me to a quandary. I've always considered the risk of glass contamination as a CCP
but our process to control this hazard is to monitor the air and water cleaning lines (depending on which line the product is running on) to ensure the pressure is within specification
and to visually inspect that the air/water cleaning equipment is working appropriately. (Empty Bottles are manually dumped from cases and then inverted and either air or water washed before being filled)
the question in our Decision Tree says " Is the frequency of monitoring/checking the control measure sufficient to enable immediate corrective action? If yes, CCP, if no OPRP.
As we do not have any sort of immediate way to tell (eg no alarms to alert if the pressure should drop below spec) , we have containment and rework procedures to deal with an eventuality of finding that the control has broken down between the hourly checks.
So, in that case, is it an OPRP - despite the fact that glass contamination is critical?
Sorry if this sounds a ridiculous question.
Eventually we will want to certify this to FSC22000 standard, but we've a ways to go yet.
Is the frequency of monitoring/checking the control measure sufficient to enable immediate corrective action If Yes, - CCP, If No - OPRP
It sounds like you need to implement some PRPs