Editor’s Note: This column is the first of two parts. Part two, which will run in our June/July issue, will discuss understanding and applying effective tools to ensure that your prerequisite programs are well defined and effective.
As hazard analysis and critical control points (HACCP) has evolved in the food industry over the past 15 years, the term “prerequisite program” has also grown in popularity and understanding. Years ago, we talked about the prerequisite programs and how these were the foundation for your HACCP programs, but most of the attention was on hazard analysis and identification of critical control points.
A critical control point (CCP) is a step in the process where control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. A prerequisite program is a program that addresses situations within the operation that ensure that possible hazards are controlled. Effective prerequisite programs are directly linked not only to the control of identified hazards but also to the effectiveness of the HACCP program overall.
In 2005, the International Organization for Standardization issued the ISO 22000 standard. This standard was the first “globally recognized food safety management systems standard that [considers] the food safety risks and impacts across the entire food supply chain.” This standard defines the operational prerequisite program (OPRP) as a plan that focuses on food safety.
IS0 22000:2005 can be defined as follows. Prerequisite program (PRP) defines the “basic conditions and activities that are necessary to maintain a hygienic environment through the food chain suitable for the production, handling, and provision of safe end products and safe food for human consumption.”
OPRP is a “PRP identified by the hazard analysis as essential in order to control the likelihood of food safety hazards and/or the contamination or proliferation of food safety hazards in the product(s) or in the processing environment.”
There is much discussion relating to the protocol for determining which factors separate a PRP from an OPRP from a CCP. It is important that we focus this article on basic prerequisite programs.
PRP Crosses Product Lines
Prerequisite programs generally cross all product lines affecting all operations, not just one specific process line or product. PRPs are usually managed system wide compared to CCPs, which are product or line specific. Examples of PRPs include good manufacturing practices (GMPs), pest control, supplier approval, and water treatment. A deviation in a prerequisite program rarely requires actions against a specific product, whereas a deviation in a CCP results in an action against the product, such as placing product on hold or performing a product recall. A deviation in an OPRP may or may not result in an action against the product, depending on the specific deviation.
Well-designed prerequisite programs provide a solid foundation for an effective HACCP program. HACCP programs do not stand alone. The National Advisory Committee on Microbiological Criteria for Foods states that the production of safe food products requires that the HACCP program be built upon a solid foundation of prerequisite programs, because “prerequisite programs provide the basic environment and operating conditions necessary for the production of safe, wholesome food.” The role of the PRP is to control or eliminate hazards wherever possible. Without well-defined, effective prerequisite programs, the HACCP program will fail.
Some PRPs are required for certain food processing segments under HACCP regulations for the U.S. Food and Drug Administration and the U.S. Department of Agriculture-Food Safety and Inspection Service. With the advent of HACCP regulations, some HACCP experts have suggested that the phrase prerequisite programs be used only for those programs required under regulation, in order to distinguish them from precursory programs, which are programs that have been deemed necessary but are not required under regulations. For the purpose of this discussion, the term prerequisite program applies to those programs that have been identified as necessary to control or eliminate a hazard in any HACCP program, whether it has been deemed regulated or not.