During the development of the HACCP program, a cross-functional team performs the hazard analysis in compliance with the requirement of the Codex Alimentarius Principle One: “Conduct a hazard analysis.” Potential hazards are identified, then evaluated to determine whether the hazard must be addressed through a CCP or OPRP, or if the hazard can actually be controlled through a prerequisite program. Control means that steps/actions/procedures are in place that ensure that the hazard does not result in a product that may cause illness or harm when consumed.
The point is that top management must ensure that resources such as time, associates, and training funds are effectively assigned to support the successful implementation and maintenance of these programs as part of management commitment.
Requirements for PRP Effectiveness
Requirements to ensure the effectiveness of the PRP, including responsibilities and required actions to be followed, must be clearly defined. These documents are most commonly referred to as standard operating procedures. Clearly defining the specific requirements, ensuring that associates are effectively trained, and evaluating results to confirm effectiveness are essential. All operations, no matter what the finished product, have some programs.
Most have written procedures and use specific forms to record the results. Are these effective? Are the requirements reflecting current activities well defined? When were the documents written? When was the last time they were reviewed to ensure that clearly defined requirements are still appropriate for current tasks? Currently, one of the most common audit findings is outdated, incomplete, and/or multiple versions of the same document.
Were the responsible associates trained on these documents, and do records prove the training took place? Another common finding is a lack of any training record(s) to confirm that the associates were trained on the requirements. The point is that top management must ensure that resources such as time, associates, and training funds are effectively assigned to support the successful implementation and maintenance of these programs as part of management commitment.
Many times, management is surprised to hear the term management commitment emphasized during HACCP training and subsequent HACCP program development activities. Although management commitment is not one of the seven principles of HACCP, Codex Alimentarius states that “management commitment is necessary for the implementation of an effective HACCP system.” It also emphasizes that “the successful application of HACCP requires the full commitment and involvement of management and the work force.”
Management must convey a positive message of commitment through all levels of the operation in both words and actions. It is recommended that management formally monitor all food safety activities on an ongoing basis through hands-on discussions with the HACCP coordinator, to ensure the continued suitability and effectiveness of its operation.
Common PRPs
Examples of PRPs common to most operations include:
GMPs as defined in 21 CFR 110 for cGMPs. GMPs are probably one of the most well-known programs. Potential hazards could be foreign materials such as jewelry, hair, or gum. An effective GMP program defines requirements for wearing jewelry, hairnets, and beard snoods, as well as for eating and/or drinking (including chewing gum) in the process areas. If this is effective, the hazard is controlled and does not have to be addressed in the HACCP program.
Pest Control: Pest control is part of basic GMP compliance. Having an effective pest control program goes beyond hiring an external company for pest control. Your pest control program must be clearly defined. A company associate must be in charge of the program, responsible for working with the external supplier to ensure the program’s total effectiveness, making sure that certain activities are performed as defined, required records such as rodent bait activity are kept, and recommendations or other concerns are addressed in a manner both timely and effective. Results from the external service company must be monitored and confirmed to be effective. An external pest control company must be approved and evaluated as an approved critical supplier. Supplier approval programs are another essential prerequisite program.
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