PAS 220 focuses on the PRPs and specific requirements. It “specifies the exact requirements for PRPs. The specification applies to all organizations, regardless of size or complexity, as well as to all who are involved in the manufacturing step of the food chain. It should be used in conjunction with ISO 22000. Its focus is to ensure that processes are in place to minimize, mitigate, or eliminate potential food safety hazards from affecting the products, including product contamination, food safety hazard levels, and the product processing environment.”
PAS 220 is an excellent document to review and incorporate into every operation, whether or not the operation is seeking certification. It is generic and provides specific requirements; however, the extent that it applies to a given manufacturing site will depend on the product being produced.
Well-defined and effective PRPs are vitally important. The most common remarks from attendees at our HACCP plan development workshops are that the first item on the “to do list” is to review the PRPs to ensure that these are really functioning in an effective manner that is best for the operation. PRPs are unique to each operation. Requirements for effective implementation and maintenance of PRPs should be written in a usable format, involve training of personnel, and define monitoring and documentation requirements. Defined requirements must also include corrective actions where appropriate to control food safety and provide for the verification of the requirements and their effectiveness.
Verification is proof that defined requirements are being performed; however, records that confirm validation must also be identified and maintained. Validation records confirm that the correct activities are being performed and include the information that is used to define the parameters of a program. Validation for PRPs is often considered less critical than validation for a CCP; however, it is still very important to justify the parameters. It is this justification that provides the foundation for decisions and challenges to your program.
No matter how large or small your operation, producing a safe product is essential. It is imperative that your operation be built on a foundation of well-defined and effective PRPs. Communicate this importance to your associates. Stop, divide your production into individual servings, then think, “How many individuals have we touched today?” The results may surprise you. ■
Resources
- Stevenson KE, Bernard DT. HACCP: A Systematic Approach to Food Safety. 3rd ed. Washington, D.C.: The Food Processors Institute; 1999.
- Pillay V, Groenveld C. Food safety goes global. Food Quality Website. February/March 2009. Available at: www.foodquality.com/mag/02012009.03012009/fq_03012009_FE3.htm. Accessed May 13, 2010.
- International Organization for Standardization (ISO). ISO 22000:2005. Food Safety Management systems—requirements for any organization in the food chain. Section 3.8. Geneva, Switzerland; 2005.
- International Organization for Standardization (ISO). ISO 22000:2005. Food Safety Management systems – requirements for any organization in the food chain. Section 3.9. Geneva, Switzerland; 2005.
- United States Department of Health and Human Services. National Advisory Committee on Microbiological Criteria for Foods (NACMCF). FDA Website. August 14, 1997. Hazard analysis and critical control point principles and application guidelines. Available at: www.fda.gov/Food/FoodSafety/HazardAnalysisCriticalControlPointsHACCP/ucm114868.htm. Accessed May 13, 2010.
- Schmidt RH, Newslow DL. Hazard analysis critical control points (HACCP)—prerequisite programs. FSHN 07-02. University of Florida IFAS Extension website. June 2007. Available at: http://edis.ifas.ufl.edu/fs138. Accessed May 13, 2010.
- U.S. Food and Drug Administration. Title 21 Code of Federal Regulations (21 CFR 110). Current good manufacturing practice in manufacturing, packing, or holding human food. FDA website. Available at: www.accessdata.fda. gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?cfrpart=110. Accessed May 13, 2010.
- Newslow DL. Effective HACCP plan: not just a fairytale. Food Quality. May/June 2002: 28-37.
- Sansawat S, Muliyil V. Understanding the FSSC 22000 Food Safety System Certification Standard. Geneva, Switzerland: SGS SA; 2009.
Newslow is a member of the Food Quality editorial advisory board and is president of D.L. Newslow & Associates Inc. Reach her at [email protected].
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