Editor’s Note: This is the second in a two-part article. The first part, “Pump Up Your Prerequisite Programs,” appeared in our April/May issue.
In a previous article, we looked at the role of prerequisite programs (PRPs) in your operation. We discussed examples and the International Organization for Standardization (ISO) 22000:2005 and Publicly Available Specification (PAS) 220:2008 standards. In this issue, we will further evaluate the necessities, including the application and integration of some effective tools into your operation.
“Well-defined” and “effective” are two adjectives used repeatedly because of the total impact they can have on your hazard analysis and critical control points (HACCP) programs and, more importantly, on the production of a safe product. A well-defined and effective program for record control is essential. Not only must a company maintain records that demonstrate compliance with the critical control points (CCPs) and direct involvement with your HACCP program, but the records must demonstrate that PRPs are being completed as defined.
If a program requires that the metal detector be checked with calibrated standards every 30 minutes, then records must be maintained to prove that this happens. If operator training is required, then records of that training must be maintained. An effective record control PRP identifies the record, the responsibility for maintaining the record, and the required retention time for keeping the record. Retention times must be realistic and provide evidence of compliance. If calibration of a retort thermometer is required annually, make certain that the records are maintained for several years to provide a comprehensive historical record that this frequency is being met.
Document Control Program
A precursor for an effective PRP is a clearly defined and effective document control program. Requirements for compliance must be written. Often, this type of document is referred to as a standard operating procedure (SOP), and SOPs must be controlled. Document control and the creation and maintenance of SOPs may be considered a PRP.
Documents must be identified and controlled to ensure that associates always have the most current document. This includes not only SOPs or other informational documents but also the forms that demonstrate compliance. A well-defined and effective document control procedure must identify both the document and responsibilities for the document, and must assure that documents are readily available to anyone who needs them in order to perform his or her area of responsibility. There must be only one version of each document: the most current version.
Training has been previously mentioned in relation to more than one program description. Actually, well-defined and effective training is a PRP that encompasses all activities within the food safety program. Required training, proof that it has been successfully completed, and evaluation of its effectiveness must be managed in a PRP. When planning your training program, keep in mind the differences between training and education. Training may be defined as a learned reaction, whereas education reflects the communication of the reason and necessity that results in an understanding of why the learned skill is important.
Other examples of PRPs may include foreign material control, water treatment, calibration, receiving inspection, storage practices, allergen control, sanitation, hazardous material control, chemical control, preventive maintenance, labeling, product identification and traceability, mock recall, cleaning, and sanitizing. The list is extensive, and actual application and severity are directly related to the nature of the product being manufactured.
Requirements for effective implementation and maintenance of prerequisite programs should be written in a usable format, involve training of personnel, and define monitoring and documentation requirements.
Review and Use PAS 220
ISO 22000:2005 combines with PAS 220:2008 to make up the requirements for Food Safety System Certification (FSSC) 22000. The Global Food Safety Initiative has approved FSSC 22000 for manufacturing companies.